ML15303A366

NRC Integrated Inspection Report 05000255/2015003

ML15303A366
Person / Time
Site:	Palisades
Issue date:	10/30/2015
From:	Eric Duncan Division Reactor Projects III
To:	Vitale A Entergy Nuclear Operations
References
IR 2015003
Download: ML15303A366 (51)

See also: IR 05000255/2015003

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

October 30, 2015

Mr. Anthony Vitale

Vice-President, Operations

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANT

NRC INTEGRATED INSPECTION REPORT 05000255/2015003

Dear Mr. Vitale:

On September 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Palisades Nuclear Plant. The enclosed report documents the results of this

inspection, which were discussed on October 29, 2015, with you and other members of your

staff.

Based on the results of this inspection, two NRC-identified findings of very low safety

significance were identified. The findings involved violations of NRC requirements. However,

because of their very low safety significance, and because the issues were entered into your

corrective action program, the NRC is treating the violations as non-cited violations (NCVs) in

accordance with Section 2.3.2 of the NRC Enforcement Policy.

If you contest the subject or severity of any NCV, you should provide a response within 30 days

of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a

copy to the Regional Administrator, U.S. Nuclear Regulatory Commission-Region III,

2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement,

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident

Inspector Office at the Palisades Nuclear Plant. In addition, if you disagree with the

cross-cutting aspect assigned to any finding in this report, you should provide a response within

30 days of the date of this inspection report, with the basis for your disagreement, to the

Regional Administrator, Region III, and the NRC Resident Inspector at the Palisades Nuclear

Plant.

A. Vitale -2-

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy

of this letter, its enclosure, and your response (if any) will be available electronically for public

inspection in the NRCs Public Document Room or from the Publicly Available Records System

(PARS) component of the NRC's Agencywide Documents Access and Management System

(ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Eric Duncan, Chief

Branch 3

Division of Reactor Projects

Docket No. 50-255

License No. DPR-20

Enclosure:

IR 05000255/2015003

w/Attachment: Supplemental Information

cc w/encl: Distribution via LISTSERV

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-255

License No: DPR-20

Report No: 05000255/2015003

Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant

Location: Covert, MI

Dates: July 1 through September 30, 2015

Inspectors: A. Nguyen, Senior Resident Inspector

J. Boettcher, Resident Inspector

B. Boston, Acting Resident Inspector

J. Cassidy, Senior Health Physicist

R. Elliott, Reactor Engineer

M. Holmberg, Reactor Inspector

J. Lennartz, Project Engineer

V. Myers, Senior Health Physicist

T. Taylor, Resident Inspector, D.C. Cook

Approved by: E. Duncan, Chief

Branch 3

Division of Reactor Projects

Enclosure

TABLE OF CONTENTS

TABLE OF CONTENTS ................................................................................................................ 1

SUMMARY OF FINDINGS ........................................................................................................... 2

REPORT DETAILS ....................................................................................................................... 4

Summary of Plant Status ........................................................................................................... 4

1. REACTOR SAFETY .................................................................................................... 4

1R04 Equipment Alignment (71111.04) ....................................................................... 4

1R05 Fire Protection (71111.05) .................................................................................. 5

1R06 Flooding (71111.06) ........................................................................................... 6

1R11 Licensed Operator Requalification Program (71111.11) .................................... 7

1R12 Maintenance Effectiveness (71111.12) .............................................................. 8

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13) ......... 9

1R15 Operability Determinations and Functional Assessments (71111.15) .............. 10

1R19 Post-Maintenance Testing (71111.19) ............................................................. 13

1R20 Outage Activities (71111.20) ............................................................................ 14

1R22 Surveillance Testing (71111.22) ....................................................................... 15

1EP6 Drill Evaluation (71114.06) ............................................................................... 16

2. RADIATION SAFETY ................................................................................................ 17

2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06) ..................... 17

4. OTHER ACTIVITIES ................................................................................................. 24

4OA1 Performance Indicator Verification (71151) ...................................................... 24

4OA2 Identification and Resolution of Problems (71152) ........................................... 27

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153) .............. 28

4OA5 Other Activities ................................................................................................. 28

4OA6 Management Meetings ..................................................................................... 28

SUPPLEMENTAL INFORMATION ............................................................................................... 1

KEY POINTS OF CONTACT..................................................................................................... 1

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED ......................................................... 2

LIST OF DOCUMENTS REVIEWED......................................................................................... 3

LIST OF ACRONYMS USED .................................................................................................. 18

SUMMARY OF FINDINGS

Inspection Report (IR) 05000255/2015003, 07/01/2015-09/30/2015; Palisades Nuclear Plant;

Operability Determinations and Functional Assessments; and Radioactive Gaseous and Liquid

Effluent Treatment.

This report covers a 3-month period of inspection by resident inspectors and announced

baseline inspections by regional inspectors. Two Green findings were identified by the

inspectors. These findings were considered non-cited violations (NCVs) of U.S. Nuclear

Regulatory Commission (NRC) regulations. The significance of inspection findings is indicated

by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using

Inspection Manual Chapter (IMC) 0609, Significance Determination Process, dated

April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the

Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are

dispositioned in accordance with the NRCs Enforcement Policy dated July 9, 2013. The NRC's

program for overseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.

Cornerstone: Mitigating Systems

Green. An NRC-identified finding of very low safety significance and an associated NCV

of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B,

Criterion III, Design Control, was identified for the failure to justify continued service of

safety-related electrolytic capacitors that were installed beyond their recommended

service life associated with the safety-related containment floor level indicating

transmitters (LITs). Specifically, on June 21, 2015, containment floor LIT LIT-0446B

and LIT-0446A did not satisfy the acceptance criteria of the technical specification

surveillance monthly channel checks and LIT-0446B was declared inoperable. Further

troubleshooting identified a failure of the electrolytic capacitor within the transmitters

converter module and that this failure was most likely due to age since the transmitter

had been in service for greater than its recommended service life. In addition to entering

this issue into their Corrective Action Program (CAP) as CR-PLP-2015-04972, the

licensee replaced the failed components and planned to develop a replacement

schedule for non-critical, safety-related electrolytic capacitors.

The performance deficiency was determined to be more than minor because it was

associated with the Equipment Performance attribute of the Mitigating Systems

cornerstone and adversely affected the cornerstone objective of ensuring the availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences (i.e., core damage). The finding screened as having very low

safety significance based on answering No to all of the screening questions in the

Mitigating Structures, Systems, and Components (SSCs) and Functionality section of

IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power,

Exhibit 1, Mitigating Systems Screening Questions. The finding had a cross-cutting

aspect of Operating Experience in the Problem Identification and Resolution

cross-cutting area because the licensee did not effectively and thoroughly evaluate and

implement relevant industry operating experience and guidance for age-related

electrolytic capacitor degradation [P.5]. (Section 1R15)

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Cornerstones: Occupational Radiation Safety and Public Radiation Safety

Green. A finding of very low safety significance and an associated NCV of Technical

Specification (TS) 5.5.1, Offsite Dose Calculation Manual, was identified for the failure

to establish, implement, and maintain the Offsite Dose Calculation Manual (ODCM)

relative to dose calculation parameters. Specifically, the licensee failed to modify the

parameters used in public radiation calculations when changes in the use of unrestricted

areas were identified. As a result, the quarterly and annual doses that were calculated

every 31 days, as required by the ODCM, were incorrect and non-conservative. In

addition to entering this issue into their CAP as CR-PLP-2015-2972, the licensee

recalculated the dose using the correct calculation parameters.

The performance deficiency was determined to be more than minor because it was

associated with the Program and Process attribute of the Public Radiation Safety

cornerstone and adversely affected the cornerstone objective of ensuring the adequate

protection of public health and safety from exposure to radioactive materials released

into the public domain as a result of routine civilian nuclear reactor operation. The

finding was determined to be of very low safety significance in accordance with

IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process,

because the issue did not represent a significant deficiency in evaluating a planned or

unplanned effluent release since the resulting dose was not grossly underestimated.

The finding had a cross-cutting aspect of Training in the Human Performance

cross-cutting area because the licensee did not ensure adequate knowledge transfer to

maintain a knowledgeable, technically competent workforce. [H.9] (Section 2RS6)

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REPORT DETAILS

Summary of Plant Status

The plant operated at or near full power during the inspection period until August 24, 2015,

when the operators entered a coastdown period in preparation for refueling outage (RFO) 1R24.

On September 16, 2015, the unit automatically tripped in response to an electrical failure in the

digital electrohydraulic control system. The unit remained shutdown and transitioned into the

RFO for the remainder of the inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R04 Equipment Alignment (71111.04)

.1 Quarterly Partial System Walkdowns

a. Inspection Scope

The inspectors performed partial system walkdowns of the following risk-significant

systems:

• Left train auxiliary feedwater system during surveillance of right train auxiliary

feedwater system;

• 1-2 diesel generator during surveillance of the 1-1 diesel generator;

• A' train shutdown cooling system during RFO 1R24; and

• Air system alignment to containment during RFO 1R24.

The inspectors selected these systems based on their risk significance relative to the

Reactor Safety Cornerstones at the time they were inspected. The inspectors attempted

to identify any discrepancies that could impact the function of the system and therefore

potentially increase risk. The inspectors reviewed applicable operating procedures,

system diagrams, the Updated Final Safety Analysis Report (UFSAR), Technical

Specification (TS) requirements, outstanding work orders (WOs), condition reports

(CRs), and the impact of ongoing work activities on redundant trains of equipment in

order to identify conditions that could have rendered the systems incapable of

performing their intended functions. The inspectors also walked down accessible

portions of the systems to verify system components and support equipment were

aligned correctly and operable. The inspectors examined the material condition of the

components and observed operating parameters of equipment to verify that there were

no obvious deficiencies. The inspectors also verified that the licensee had properly

identified and resolved equipment alignment problems that could cause initiating events

or impact the capability of mitigating systems or barriers and entered them into the

Corrective Action Program (CAP) with the appropriate significance characterization.

Documents reviewed are listed in the Attachment to this report.

These activities constituted four partial system walkdown samples as defined in

Inspection Procedure (IP) 71111.04-05.

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b. Findings

No findings were identified.

.2 Semiannual Complete System Walkdown

a. Inspection Scope

Between July 21 and August 12, 2015, the inspectors performed a complete system

alignment inspection of the service water system to verify the functional capability of the

system. This system was selected because it was considered both safety-significant

and risk-significant in the licensees probabilistic risk assessment. The inspectors

walked down the system to review mechanical and electrical equipment lineups;

electrical power availability; system pressure and temperature indications; component

labeling; component lubrication; component and equipment cooling; hangers and

supports; operability of support systems; and to ensure that ancillary equipment or

debris did not interfere with equipment operation. A review of a sample of past and

outstanding WOs was performed to determine whether any deficiencies significantly

affected the system function. In addition, the inspectors reviewed the CAP database to

ensure that system equipment alignment problems were being identified and

appropriately resolved. Documents reviewed are listed in the Attachment to this report.

These activities constituted one complete system walkdown sample as defined in

IP 71111.04-05.

b. Findings

No findings were identified.

1R05 Fire Protection (71111.05)

a. Inspection Scope

The inspectors conducted fire protection walkdowns which were focused on the

availability, accessibility, and the condition of firefighting equipment in the following

risk-significant plant areas:

• Fire Area 16: component cooling water (CCW) pump room;

• Fire Area 9: screenhouse;

• Fire Area 10: east engineered safeguards room;

• Risk-significant fire areas during the higher risk plant operating state #1 of

RFO 1R24;

• Fire Areas 29, 30, and 31: electrical and mechanical equipment rooms; and

• Fire Area 6: diesel generator 1-2 and fuel oil day tank room.

The inspectors reviewed areas to assess if the licensee had implemented a fire

protection program that adequately controlled combustibles and ignition sources within

the plant, effectively maintained fire detection and suppression capability, maintained

passive fire protection features in good material condition, and implemented adequate

compensatory measures for out-of-service, degraded, or inoperable fire protection

equipment, systems, or features in accordance with the licensees fire plan.

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The inspectors selected fire areas based on their overall contribution to internal fire risk

as documented in the plants Individual Plant Examination of External Events with later

additional insights, their potential to impact equipment which could initiate or mitigate a

plant transient, or their impact on the plants ability to respond to a security event.

Using the documents listed in the Attachment to this report, the inspectors verified that

fire hoses and extinguishers were in their designated locations and available for

immediate use; that fire detectors and sprinklers were unobstructed; that transient

material loading was within the analyzed limits; and fire doors, dampers, and penetration

seals appeared to be in satisfactory condition. The inspectors also verified that minor

issues identified during the inspection were entered into the licensees CAP.

These activities constituted six quarterly fire protection inspection samples as defined in

IP 71111.05-05.

b. Findings

No findings were identified.

1R06 Flooding (71111.06)

.1 Internal Flooding

a. Inspection Scope

The inspectors reviewed selected risk-important plant design features and licensee

procedures intended to protect the plant and its safety-related equipment from internal

flooding events. The inspectors reviewed flood analyses and design documents,

including the UFSAR, engineering calculations, and abnormal operating procedures to

identify licensee commitments. The inspectors also reviewed the licensees corrective

action documents with respect to past flood-related items identified in the CAP to verify

the adequacy of the corrective actions. The inspectors performed a walkdown of the

following plant area to assess the adequacy of watertight doors and verify drains and

sumps were clear of debris and were operable, and that the licensee complied with its

commitments:

• cable spreading room.

Documents reviewed during this inspection are listed in the Attachment to this report.

This inspection constituted one internal flooding sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

.2 Underground Vaults

a. Inspection Scope

The inspectors selected underground bunkers/manholes subject to flooding that

contained cables whose failure could disable risk-significant equipment. The inspectors

determined whether the cables were submerged, whether splices were intact, and

whether appropriate cable support structures were in place. In those areas where

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dewatering devices were used, such as a sump pump, the inspectors determined

whether the device was operable and level alarm circuits were set appropriately to

ensure that the cables would not be submerged. In those areas without dewatering

devices, the inspectors verified that drainage of the area was available, or that the

cables were qualified for submerged conditions. The inspectors also reviewed the

licensees corrective action documents with respect to past submerged cable issues

identified in the CAP to verify the adequacy of the corrective actions. The inspectors

performed a walkdown of the following underground bunkers/manholes subject to

flooding:

• Manhole #4 and Manhole #8.

Documents reviewed are listed in the Attachment to this report. This inspection

constituted one underground vaults sample as defined in IP 71111.06-05.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program (71111.11)

.1 Resident Inspector Quarterly Review of Licensed Operator Requalification (71111.11Q)

a. Inspection Scope

On August 5, 2015, the inspectors observed a crew of licensed operators in the plants

simulator during licensed operator requalification training. The inspectors verified that

operator performance was adequate, evaluators were identifying and documenting crew

performance problems, and that training was being conducted in accordance with

licensee procedures. The inspectors evaluated the following areas:

• licensed operator performance;

• crews clarity and formality of communications;

• the ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of abnormal and emergency procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• the ability to identify and implement appropriate TS actions and Emergency Plan

actions and notifications.

Crew performance in these areas was compared to pre-established operator action

expectations and successful critical task completion requirements. Documents reviewed

are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator requalification program

simulator sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

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.2 Resident Inspector Quarterly Observation During Periods of Heightened Activity or Risk

(71111.11Q)

a. Inspection Scope

On September 16, 2015, the inspectors observed a reactor cooldown to Mode 5

following a reactor trip. This was an activity that required heightened awareness or was

related to increased risk. The inspectors evaluated the following areas:

• licensed operator performance;

• the crews clarity and formality of communications;

• ability to take timely actions in the conservative direction;

• prioritization, interpretation, and verification of annunciator alarms;

• correct use and implementation of procedures;

• control board manipulations;

• oversight and direction from supervisors; and

• the ability to identify and implement appropriate TS actions and Emergency Plan

actions and notifications.

Performance in these areas was compared to pre-established operator action

expectations, procedural compliance, and task completion requirements. Documents

reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly licensed operator heightened activity/risk

sample as defined in IP 71111.11-05.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors evaluated degraded performance issues involving the following

risk-significant system:

• containment personnel inner air lock door.

The inspectors reviewed events including those in which ineffective equipment

maintenance resulted in valid or invalid automatic actuations of engineered safeguards

systems and independently verified the licensee's actions to address system

performance or condition problems in terms of the following:

• implementing appropriate work practices;

• identifying and addressing common cause failures;

• scoping of systems in accordance with Title 10 of the Code of Federal

Regulations (10 CFR) 50.65(b) of the maintenance rule;

• characterizing system reliability issues for performance;

• charging unavailability for performance;

• trending key parameters for condition monitoring;

8

• ensuring 10 CFR 50.65(a)(1) or (a)(2) classification or re-classification; and

• verifying appropriate performance criteria for structures, systems, and

components (SSCs)/functions classified as (a)(2), or appropriate and adequate

goals and corrective actions for systems classified as (a)(1).

The inspectors assessed performance issues with respect to the reliability, availability,

and condition monitoring of the system. In addition, the inspectors verified maintenance

effectiveness issues were entered into the CAP with the appropriate significance

characterization. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one quarterly maintenance effectiveness sample as defined

in IP 71111.12-05.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed the licensee's evaluation and management of plant risk for the

maintenance and emergent work activities affecting risk-significant and safety-related

equipment listed below to verify that appropriate risk assessments were performed prior

to removing equipment for work:

• breaker 72-13, A primary coolant pump (PCP) direct current oil lift pump,

removal;

• purification demineralizer filter replacement;

• diving in the spent fuel pool tilt pit;

• reduced inventory period #1 during RFO; and

• emergent work to uncouple control rod drive 11.

These activities were selected based on their potential risk significance relative to the

Reactor Safety Cornerstones. As applicable for each activity, the inspectors verified that

risk assessments were performed as required by 10 CFR 50.65(a)(4) and were accurate

and complete. When emergent work was performed, the inspectors verified that the

plant risk was promptly reassessed and managed. The inspectors reviewed the scope

of maintenance work, discussed the results of the assessment with the licensee's

probabilistic risk analyst or shift technical advisor, and verified plant conditions were

consistent with the risk assessment. The inspectors also reviewed TS requirements and

walked down portions of redundant safety systems, when applicable, to verify risk

analysis assumptions were valid and applicable requirements were met.

Documents reviewed are listed in the Attachment to this report. These maintenance risk

assessments and emergent work control activities constituted five samples as defined in

IP 71111.13-05.

b. Findings

No findings were identified.

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1R15 Operability Determinations and Functional Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed the following issues:

• primary cooling system (PCS) branch connection weld inspection calculation

errors;

• fuel oil transfer system operability;

• A PCP decreasing lower bearing oil level trend; and

• containment level indicating transmitter (LIT) capacitor failure.

The inspectors selected these potential operability issues based on the risk significance

of the associated components and systems. The inspectors evaluated the technical

adequacy of the evaluations to ensure that TS operability was properly justified and the

subject component or system remained available such that no unrecognized increase in

risk occurred. The inspectors compared the operability and design criteria in the

appropriate sections of the TS and UFSAR to the licensees evaluations to determine

whether the components or systems were operable. Where compensatory measures

were required to maintain operability, the inspectors determined whether the measures

in place would function as intended and were properly controlled. The inspectors

determined, where appropriate, compliance with bounding limitations associated with the

evaluations. Additionally, the inspectors reviewed a sample of corrective action

documents to verify that the licensee was identifying and correcting any deficiencies

associated with operability evaluations. Documents reviewed are listed in the

Attachment to this report.

This operability inspection constituted three samples as defined in IP 71111.15-05. The

sample for the weld inspection calculation error was accounted for in Inspection Report

(IR) 05000255/2015012.

b. Findings

Introduction. An NRC-identified finding of very low safety significance (Green) and an

associated Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design

Control, was identified for the failure to justify continued service of safety-related

electrolytic capacitors installed beyond their recommended service life associated with

containment floor LITs LIT-0446B

and LIT-0446A.

Description. During the performance of monthly operations TS surveillance test MO-45,

Control Room Channel Checks, on June 21, 2015, LIT-0446B, the B containment LIT,

was found to be indicating below the acceptance criteria minimum required value. The

transmitter was declared inoperable in accordance with TS 3.3.7, Post Accident

Monitoring, since the accuracy over the entire level span of the instrument was

considered degraded such that it could no longer perform its function to accurately

monitor containment water level as specified by Regulatory Guide 1.97. These

containment LITs are relied upon in the plants emergency operating procedures to

ensure adequate net positive suction head for emergency core cooling system (ECCS)

pumps following receipt of a recirculation actuation signal (RAS).

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On July 16, 2015, further troubleshooting was conducted and determined that the

electrolytic capacitor within the transmitters converter module failed and the most likely

cause of the capacitor failure was operation beyond the components service life since

the LITs had been in service for greater than 10 years. Entergy subsequently submitted

letter PNP 2015-058 to the NRC on August 3, 2015, reporting this information as

required by TS 5.6.6. This specification states that if post-accident monitoring

instrumentation is inoperable, a preplanned alternate method of monitoring, the cause of

the inoperability, and the schedule for restoring the inoperable instrument to an operable

status shall be submitted in a report to the NRC.

The resident inspectors asked follow-up questions associated with industry operating

experience and the preventive maintenance program for these transmitters. These LITs

were replaced on an as-required basis (no preventive maintenance frequency) and

were classified as non-critical components in the licensees maintenance program.

However, industry operating experience and Electric Power Research Institute guidance

was found by the inspectors that indicated electrolytic capacitors have a specified

lifespan based on operating conditions and applications. The NRC issued Information

Notice (IN) 2012-11, Age-Related Capacitor Degradation, in July 2012, which also

informed licensees of problems that involved the age-related degradation of capacitors.

The licensee documented a review of this IN in CR-PLP-2012-5721. However, the

licensees preventive maintenance interval review of this operating experience only

considered electrolytic capacitors that were classified as critical components in their

maintenance rule program. The capacitors which were identified during this review were

scheduled for, at most, 10 year replacement intervals. The licensee potentially missed

the opportunity to establish a replacement program for these transmitters at that time. In

addition to entering this issue into their CAP as CR-PLP-2015-04972, the licensee

replaced the failed components and planned to develop a replacement schedule for

non-critical, safety-related electrolytic capacitors.

Analysis. The inspectors determined that the failure to review for suitability of

application of the safety-related electrolytic capacitors in the containment floor LITs,

which were installed beyond their recommended service life, was contrary to

10 CFR Part 50, Appendix B, Criterion III, Design Control, and was a performance

deficiency.

The inspectors determined that the performance deficiency was more than minor in

accordance with Inspection Manual Chapter (IMC) 0612 "Power Reactor Inspection

Reports," Appendix B, "Issue Screening," dated September 7, 2012, because the

performance deficiency was associated with the Equipment Performance attribute of the

Mitigating Systems cornerstone and adversely affected the cornerstone objective of

ensuring the availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences (i.e., core damage). The containment

water LITs are relied upon in the plants emergency operating procedures to ensure

adequate net positive suction head for ECCS pumps following a RAS. The finding was

screened in accordance with IMC 0609, Appendix A, The Significance Determination

Process for Findings At-Power, Exhibit 1, Mitigating Systems Screening Questions,

dated July 1, 2012. The finding screened as having very low safety significance

(i.e., Green) based on answering No to all the screening questions under the Mitigating

SSCs and Functionality section of IMC 0609, Appendix A, Exhibit 1.

11

The finding had a cross-cutting aspect of Operating Experience in the Problem

Identification and Resolution cross-cutting area since the licensee did not effectively and

thoroughly evaluate and implement relevant industry operating experience and guidance

for age-related electrolytic capacitor degradation [P.5].

Enforcement. 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part,

that measures shall be established for the selection and review for suitability of

application of materials, parts, equipment, and processes that are essential to the

safety-related functions of SSCs.

Contrary to the above, as of June 21, 2015, the licensee failed to review for suitability of

application of parts essential to the safety-related functions of the containment floor level

indicating system. Specifically, the licensee did not review for suitability of application of

safety-related electrolytic capacitors in the containment floor LITs that were installed

beyond their recommended service life to justify their continued service considering

in-service deterioration. As part of their immediate corrective actions, the licensee

replaced the failed components. Because this violation was of very low safety

significance and it was entered into the licensees CAP as CR-PLP-2015-04972, it is

being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.

(NCV 05000255/2015003-01 Failure to Justify Continued Service of Safety-Related

Electrolytic Capacitors Installed Beyond Their Service Life)

.2 Review of Operator Workarounds

a. Inspection Scope

Operator workarounds are operator actions taken to compensate for degraded or

non-conforming conditions. Operator workarounds that cannot be implemented

effectively can contribute to an increase in overall plant risk. The inspectors verified that

the licensee was identifying operator workarounds at an appropriate threshold, entering

them into their CAP, and had planned or taken appropriate corrective actions. As part of

their review, the inspectors considered all existing plant conditions and the cumulative

impact of all operator workarounds.

The inspectors evaluated the licensee's operator workarounds to determine if any

mitigating system functions were adversely impacted. Additionally, the inspectors

assessed whether or not the operator workarounds had adversely impacted the

operators ability to implement abnormal or emergency operating procedures. The

inspectors placed particular emphasis on any operator workarounds that had not been

effectively evaluated by the licensee; that had been formalized or proceduralized as the

long-term corrective actions for a degraded or nonconforming condition; and that may

have increased the potential for human error, such as operator workarounds that:

• Required operations that were not consistent with current training and system

knowledge;

• Required a change from long-standing operational practices;

• Required operation of a system or component in a manner that was inconsistent

with similar systems or components;

• Created the potential for the compensatory action to be performed on equipment

or under conditions for which it was not appropriate;

12

• Impaired access to required indications, increased dependence on oral

communications, or impacted the timeliness of time-critical event mitigating

actions under adverse environmental conditions;

• Required the use of equipment and interfaces that had not been designed with

consideration of the task being performed;

• Required the licensee to assess and manage an increase in risk; or

• Required a license amendment in accordance with 10 CFR 50.59, but were

implemented without an approved amendment.

Documents reviewed are listed in the Attachment to this report. These activities by the

inspectors constituted a single operator workarounds review inspection sample as

required by IP 71111.15, Section 02.01(a).

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed the following post-maintenance testing activities to verify that

procedures and testing activities were adequate to ensure system operability and

functional capability:

• CVCO-4, pump testing, following C charging pump bladder replacement;

• MI-43, instrument calibration, following replacement of the reactor vessel level

indicating system power supply;

• valve testing following repairs to the charging system surge tank vent valve; and

• diagnostic and stroke testing of service water control valves replaced on the

CCW heat exchanger during RFO 1R24.

These activities were selected based upon the SSCs ability to impact risk. The

inspectors evaluated these activities for the following (as applicable): the effect of

testing on the plant had been adequately addressed; testing was adequate for the

maintenance performed; acceptance criteria were clear and demonstrated operational

readiness; test instrumentation was appropriate; tests were performed as written in

accordance with properly reviewed and approved procedures; equipment was returned

to its operational status following testing (temporary modifications or jumpers required

for test performance were properly removed after test completion); and test

documentation was properly evaluated. The inspectors evaluated the activities against

TSs, the UFSAR, 10 CFR Part 50 requirements, licensee procedures, and various

NRC generic communications to ensure that the test results adequately ensured that the

equipment met the licensing basis and design requirements. In addition, the inspectors

reviewed corrective action documents associated with post-maintenance tests to

determine whether the licensee was identifying problems and entering them in the CAP

and that the problems were being corrected commensurate with their importance to

safety. Documents reviewed are listed in the Attachment to this report.

This inspection constituted four post-maintenance testing samples as defined in

IP 71111.19-05.

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b. Findings

No findings were identified.

1R20 Outage Activities (71111.20)

.1 Refueling Outage Activities

a. Inspection Scope

The inspectors evaluated outage activities for RFO 24 (RFO 1R24) that began on

September 16, 2015, and continued through the end of the assessment period. The

RFO began when the reactor tripped following a turbine trip due to a digital

electrohydraulic control system failure on September 16, 2015. The licensee continued

the plant shutdown to cold shutdown conditions to begin the RFO.

The inspectors reviewed the Outage Risk Assessment (ORAT) and contingency plans

for 1R24, prior to the shutdown, to confirm that the licensee had appropriately

considered risk, industry operating experience, and previous site-specific problems in

developing and implementing a plan that assured maintenance of defense-in-depth.

During the RFO, the inspectors observed portions of the shutdown and cooldown

processes and monitored licensee controls over the RFO activities listed below:

• licensee configuration management, including maintenance of defense-in-depth

commensurate with the ORAT for key safety functions and compliance with the

applicable TSs when taking equipment out of service;

• implementation of clearance activities and confirmation that tags were properly

hung and equipment appropriately configured to safely support the work or

testing;

• installation and configuration of primary coolant pressure, level, and temperature

instruments to provide accurate indication, accounting for instrument error;

• controls over the status and configuration of electrical systems to ensure that

TS and ORAT requirements were met, and controls over switchyard activities;

• monitoring of decay heat removal processes, systems, and components;

• controls to ensure that RFO work was not impacting the ability of the operators to

operate the spent fuel pool cooling system;

• reactor water inventory controls including flow paths, configurations, and

alternative means for inventory addition, and controls to prevent inventory loss;

• controls over activities that could affect reactivity;

• maintenance of secondary containment as required by TSs;

• licensee fatigue management, as required by 10 CFR 26, Subpart I; and

• licensee identification and resolution of problems related to RFO activities.

Documents reviewed are listed in the Attachment to this report. Since the RFO

extended into the fourth quarter of 2015, these activities do not count as an inspection

sample this quarter, but will be counted next quarter.

b. Findings

No findings were identified.

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1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors reviewed the test results for the following activities to determine whether

risk-significant systems and equipment were capable of performing their intended safety

function and to verify testing was conducted in accordance with applicable procedural

and TS requirements:

• RI-99, left channel nuclear instrumentation calibration (routine);

• EA-12, protective relay functional testing (routine);

• local leak rate test of containment personnel air lock (routine);

• PCS leak rate calculation (PCS leak detection);

• QO-16C, containment spray pump inservice surveillance testing (inservice test);

• RT-202, control room heating, ventilation, and air conditioning heat removal

capability testing (routine);

• RT-8D, right train engineered safeguards system integrated test (routine);

• RO-105, safety injection tank full flow inservice test (routine); and

• RO-141, containment sump check valve inservice test (containment isolation

valve).

The inspectors observed in-plant activities and reviewed procedures and associated

records to determine the following:

• did preconditioning occur;

• were the effects of the testing adequately addressed by control room personnel

or engineers prior to the commencement of the testing;

• were acceptance criteria clearly stated, sufficient to demonstrate operational

readiness, and consistent with the system design basis;

• was plant equipment calibration correct, accurate, and properly documented;

• were as-left setpoints within required ranges; and was the calibration frequency

in accordance with TSs, the UFSAR, plant procedures, and applicable

commitments;

• was measuring and test equipment calibration current;

• was the test equipment used within the required range and accuracy and were

applicable prerequisites described in the test procedures satisfied;

• did test frequencies meet TS requirements to demonstrate operability and

reliability;

• were tests performed in accordance with the test procedures and other

applicable procedures;

• were jumpers and lifted leads controlled and restored where used;

• were test data and results accurate, complete, within limits, and valid;

• was test equipment removed following testing;

• where applicable for inservice testing activities, was testing performed in

accordance with the applicable version of Section XI of the American Society of

Mechanical Engineers Code, and were reference values consistent with the

system design basis;

• was the unavailability of the tested equipment appropriately considered in the

performance indicator (PI) data;

15

• where applicable, were test results not meeting acceptance criteria addressed

with an adequate operability evaluation, or was the system or component

declared inoperable;

• where applicable for safety-related instrument control surveillance tests, was the

reference setting data accurately incorporated into the test procedure;

• was equipment returned to a position or status required to support the

performance of its safety function following testing;

• were all problems identified during the testing appropriately documented and

dispositioned in the licensees CAP;

• where applicable, were annunciators and other alarms demonstrated to be

functional and were annunciator and alarm setpoints consistent with design

documents; and

• where applicable, were alarm response procedure entry points and actions

consistent with the plant design and licensing documents.

Documents reviewed are listed in the Attachment to this report. This inspection

constituted six routine surveillance testing samples, one in-service test sample, one

reactor coolant system leak detection inspection sample, and one containment isolation

valve sample as defined in IP 71111.22, Sections-02 and-05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation (71114.06)

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine licensee emergency drill on

August 26, 2015, to identify any weaknesses and deficiencies in classification,

notification, and protective action recommendation development activities. The

inspectors observed emergency response operations in the emergency operations

facility, technical support center, and the control room simulator to determine whether

the event classification, notifications, and protective action recommendations were

performed in accordance with procedures. The inspectors also attended the licensee

drill critique to compare any inspector-observed weakness with those identified by the

licensee staff in order to evaluate the critique and to verify whether the licensee staff was

properly identifying weaknesses and entering them into the CAP. As part of the

inspection, the inspectors reviewed the drill package and other documents listed in the

Attachment to this report.

This emergency preparedness drill inspection constituted one sample as defined in

IP 71114.06-06.

b. Findings

No findings were identified.

16

2. RADIATION SAFETY

2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

This inspection constituted one complete sample as defined in IP 71124.06-05.

.1 Inspection Planning and Program Reviews (02.01)

Event Report and Effluent Report Reviews

a. Inspection Scope

The inspectors reviewed the Radiological Effluent Release Reports issued since the last

inspection to determine if the reports were submitted as required by the Offsite Dose

Calculation Manual (ODCM)/TSs. The inspectors reviewed anomalous results,

unexpected trends, or abnormal releases identified by the licensee for further inspection

to determine if they were evaluated, were entered in the CAP, and were adequately

resolved.

The inspectors selected radioactive effluent monitor operability issues reported by the

licensee as provided in effluent release reports, to review these issues during the onsite

inspection, as warranted, given their relative significance, and determine if the issues

were entered into the CAP and adequately resolved.

b. Findings

No findings were identified.

Offsite Dose Calculation Manual and Final Safety Analysis Report Review

a. Inspection Scope

The inspectors reviewed UFSAR descriptions of the radioactive effluent monitoring

systems, treatment systems, and effluent flow paths so they could be evaluated during

inspection walkdowns.

The inspectors reviewed changes to the ODCM made by the licensee since the last

inspection against the guidance in NUREG-1301, 1302, and 0133, and Regulatory

Guides 1.109, 1.21, and 4.1. When differences were identified, the inspectors reviewed

the technical basis or evaluations of the change during the onsite inspection to

determine whether they were technically justified and maintain effluent releases

as-low-as-reasonably-achievable.

The inspectors reviewed licensee documentation to determine if the licensee has

identified any non-radioactive systems that have become contaminated as disclosed

either through an event report or the ODCM since the last inspection. This review

provided an intelligent sample list for the onsite inspection of any 10 CFR 50.59

evaluations, and allowed a determination if any newly contaminated systems have an

unmonitored effluent discharge path to the environment, whether any required ODCM

revisions were made to incorporate these new pathways, and whether the associated

effluents were reported in accordance with Regulatory Guide 1.21.

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b. Findings

No findings were identified.

Groundwater Protection Initiative Program

a. Inspection Scope

The inspectors reviewed reported groundwater monitoring results and changes to the

licensees written program for identifying and controlling contaminated spills/leaks to

groundwater.

b. Findings

No findings were identified.

Procedures, Special Reports, and Other Documents

a. Inspection Scope

The inspectors reviewed Licensee Event Reports, event reports, and/or special reports

related to the Effluent Program issued since the previous inspection to identify any

additional focus areas for the inspection based on the scope/breadth of problems

described in these reports.

The inspectors reviewed the Effluent Program implementing procedures, particularly

those associated with effluent sampling, effluent monitor set-point determinations, and

dose calculations.

The inspectors reviewed copies of licensee and third party (independent) evaluation

reports of the Effluent Monitoring Program since the last inspection to gather insights

into the licensees program, and aid in selecting areas for inspection review (smart

sampling).

b. Findings

No findings were identified.

.2 Walkdowns and Observations (02.02)

a. Inspection Scope

The inspectors walked down selected components of the gaseous and liquid discharge

systems to evaluate whether equipment configuration and flow paths align with the

documents reviewed in 02.01 above, and to assess equipment material condition.

Special attention was made to identify potential unmonitored release points (such as

open roof vents in boiling water reactor turbine decks, temporary structures butted

against turbine, auxiliary or containment buildings), building alterations which could

impact airborne, or liquid effluent controls, and ventilation system leakage that

communicates directly with the environment.

18

For equipment or areas associated with the systems selected for review that were not

readily accessible due to radiological conditions, the inspectors reviewed the licensee's

material condition surveillance records, as applicable.

The inspectors walked down filtered ventilation systems to assess for conditions such as

degraded high-efficiency particulate air/charcoal banks, improper alignment, or system

installation issues that would impact the performance or the effluent monitoring capability

of the effluent system.

As available, the inspectors observed selected portions of the routine processing and

discharge of radioactive gaseous effluent (including sample collection and analysis) to

evaluate whether appropriate treatment equipment was used, and the processing

activities align with discharge permits.

The inspectors determined if the licensee had made significant changes to their effluent

release points (e.g., changes subject to a 10 CFR 50.59 review, or require NRC

approval of alternate discharge points).

As available, the inspectors observed selected portions of the routine processing and

discharging of liquid waste (including sample collection and analysis) to determine if

appropriate effluent treatment equipment was being used, and that radioactive liquid

waste was being processed and discharged in accordance with procedure requirements

and aligned with discharge permits.

b. Findings

No findings were identified.

.3 Sampling and Analyses (02.03)

a. Inspection Scope

The inspectors selected effluent sampling activities, consistent with smart sampling, and

assessed whether adequate controls have been implemented to ensure representative

samples were obtained (e.g., provisions for sample line flushing, vessel recirculation,

composite samplers, etc.).

The inspectors selected effluent discharges made with inoperable (declared

out-of-service) effluent radiation monitors to assess whether controls were in place to

ensure compensatory sampling was performed consistent with the radiological effluent

TSs/ODCM, and that those controls were adequate to prevent the release of

unmonitored liquid and gaseous effluents.

The inspectors determined whether the facility was routinely relying on the use of

compensatory sampling in lieu of adequate system maintenance, based on the

frequency of compensatory sampling since the last inspection.

The inspectors reviewed the results of the Inter-Laboratory Comparison Program to

evaluate the quality of the radioactive effluent sample analyses, and assessed whether

the Inter-Laboratory Comparison Program included hard-to-detect isotopes as

appropriate.

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b. Findings

No findings were identified.

.4 Instrumentation and Equipment (02.04)

Effluent Flow Measuring Instruments

a. Inspection Scope

The inspectors reviewed the methodology the licensee used to determine the effluent

stack and vent flow rates to determine if the flow rates were consistent with radiological

effluent TSs/ODCM or UFSAR values, and that differences between assumed and

actual stack, and vent flow rates did not affect the results of the projected public doses.

b. Findings

No findings were identified.

Air Cleaning Systems

a. Inspection Scope

The inspectors assessed whether surveillance test results since the previous inspection

for TS required ventilation effluent discharge systems (high-efficiency particulate air and

charcoal filtration), such as the Standby Gas Treatment System, and the Containment/

Auxiliary Building Ventilation System, met TS acceptance criteria.

b. Findings

No findings were identified.

.5 Dose Calculations (02.05)

a. Inspection Scope

The inspectors reviewed all significant changes in reported dose values compared to the

previous Radiological Effluent Release Report (e.g., a factor of five, or increases that

approach Appendix I criteria) to evaluate the factors, which may have resulted in the

change.

The inspectors reviewed radioactive liquid and gaseous waste discharge permits to

assess whether the projected doses to members of the public were accurate and based

on representative samples of the discharge path.

The inspectors evaluated the methods used to determine the isotopes that are included

in the source term to ensure all applicable radionuclides are included within detectability

standards. The review included the current Part 61 analyses to ensure hard-to-detect

radionuclides are included in the source term.

The inspectors reviewed changes in the licensees offsite dose calculations since the

last inspection to evaluate whether changes were consistent with the ODCM and,

Regulatory Guide 1.109. Inspectors reviewed meteorological dispersion and deposition

20

factors used in the ODCM and effluent dose calculations to evaluate whether

appropriate factors were being used for public dose calculations.

The inspectors reviewed the latest Land Use Census to assess whether changes

(e.g., significant increases or decreases to population in the plant environs, changes

in critical exposure pathways, the location of nearest member of the public, or critical

receptor, etc.) have been factored into the dose calculations.

For the releases reviewed above, the inspectors evaluated whether the calculated doses

(monthly, quarterly, and annual dose) were within the 10 CFR Part 50, Appendix I, and

TS dose criteria.

The inspectors reviewed, as available, records of any abnormal gaseous or liquid tank

discharges (e.g., discharges resulting from misaligned valves, valve leak-by, etc.) to

ensure the abnormal discharge was monitored by the discharge point effluent monitor.

Discharges made with inoperable effluent radiation monitors, or unmonitored leakages

were reviewed to ensure that an evaluation was made of the discharge to satisfy

10 CFR 20.1501 so as to account for the source term and projected doses to the public.

b. Findings

Introduction: The inspectors identified a finding of very low safety significance (Green)

and an associated NCV of TS 5.5.1, Offsite Dose Calculation Manual, for the failure to

establish, implement, and maintain the ODCM relative to dose calculation parameters.

Specifically, the licensee failed to modify the parameters used in public radiation

calculations when changes in the use of unrestricted areas were identified.

Description: The NRC requires that the licensee identify changes in the use of

unrestricted areas to permit modifications in monitoring programs for evaluating doses to

individuals from principal pathways of exposure. This was described as the Land Use

Census, in the ODCM.

The licensee completed the land use census in September/October 2014 using licensee

procedure CH 6.41 Land Use Census. The procedure also directed that any changes

to critical receptors or X/Q values that modify offsite dose calculations due to the land

use census be effective January 1 of the year following the land use census. Although

this was normal and expected, the new and sometimes more restrictive values were not

transferred to the offsite dose calculation software, GASPAR. As a result, the quarterly

and annual doses that were calculated every 31 days, as required by the ODCM, were

incorrect and non-conservative.

Discussions with the licensee revealed that the Radiological Effluent Technical

Specification (RETS) Radiological Environmental Monitoring Program (REMP) Specialist

assumed the duties and responsibilities of this position in November 2014; months after

the previous RETS-REMP Specialist had left the organization. The new individual was

aware that the land use census had been completed, but did not realize the results were

not incorporated into the program for evaluating doses to individuals from principal

pathways of exposure. As part of their immediate corrective actions, the licensee

entered this issue into their CAP as CR-2015-2972 and recalculated the dose using the

correct calculation parameters.

21

Analysis: The inspectors determined that the failure to establish, implement, and

maintain the dose calculation parameters of the ODCM was not in accordance with

TS 5.5.1, and was a performance deficiency.

The inspectors determined that the performance deficiency was more than minor

because it was associated with the Program and Process attribute of the Public

Radiation Safety cornerstone and adversely affected the cornerstone objective of

ensuring the adequate protection of public health and safety from exposure to

radioactive materials released into the public domain as a result of routine civilian

nuclear reactor operation. Specifically, the non-conservative calculation of dose to

members of the public impeded the ability to provide adequate protection of public health

and safety from exposure to radioactive materials released into the public domain as a

result of routine civilian nuclear reactor operations. The finding was assessed using

IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process,

and was determined to be of very low safety significance (Green) because the issue did

not represent a significant deficiency in evaluating a planned or unplanned effluent

release since the resulting dose was not grossly underestimated.

As described above, the cause for this failure was attributed to the lack of turnover to the

new program owner from the previous program owner. As a result, the finding had a

cross-cutting aspect of Training in the Human Performance cross-cutting area because

the licensee did not ensure adequate knowledge transfer to maintain a knowledgeable,

technically competent workforce. (H.9).

Enforcement: TS 5.5.1, Offsite Dose Calculation Manual, requires the licensee to

establish, implement, and maintain the ODCM. ODCM,Section I.B, required dose rates

to be calculated for: (1) noble gases and (2) iodines and particulates. Dose rates as

defined in this section are based on 10 CFR 50, Appendix I, limits of millirem per quarter

and millirem per year. All dose pathways of major importance in the Palisades Nuclear

Plant environs are considered, and are to be evaluated at the offsite exposure points

where maximum concentrations are expected to exist (overland sector site boundaries)

and nearest residents.

Contrary to the above, between January 1 and July 16, 2015, the licensee failed to

calculate the dose rates from noble gases, iodines, and particulates to the nearest

resident. As part of their immediate corrective actions, the licensee recalculated the

dose using the correct calculation parameters. Because this violation was of very low

safety significance and was entered into the licensees CAP as CR-2015-2972, this

violation is being treated as an NCV, consistent with Section 2.3.2.a of the NRC

Enforcement Policy. (NCV 05000255/2015003-02, Failure to Establish, Implement,

and Maintain the ODCM Relative to Dose Calculation Parameters)

22

.6 Groundwater Protection Initiative Implementation (02.06)

a. Inspection Scope

The inspectors reviewed monitoring results of the Groundwater Protection Initiative to

determine if the licensee had implemented its program as intended, and to identify any

anomalous results. For anomalous results or missed samples, the inspectors assessed

whether the licensee had identified and addressed deficiencies through its CAP.

The inspectors reviewed identified leakage or spill events and entries made into

10 CFR 50.75(g) records. The inspectors reviewed evaluations of leaks or spills and

reviewed any remediation actions taken for effectiveness. The inspectors reviewed

onsite contamination events involving contamination of ground water and assessed

whether the source of the leak or spill was identified and mitigated.

For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, the

inspectors assessed whether an evaluation was performed to determine the type and

amount of radioactive material that was discharged by:

• assessing whether sufficient radiological surveys were performed to evaluate the

extent of the contamination and the radiological source term and assessing

whether a survey/evaluation had been performed to include consideration of

hard-to-detect radionuclides; and

• determining whether the licensee completed offsite notifications, as provided in

its Groundwater Protection Initiative implementing procedures.

The inspectors reviewed the evaluation of discharges from onsite surface water bodies

that contained or potentially contained radioactivity, and the potential for groundwater

leakage from these onsite surface water bodies. The inspectors assessed whether the

licensee was properly accounting for discharges from these surface water bodies as part

of their Effluent Release Reports.

The inspectors assessed whether onsite groundwater sample results and a description

of any significant onsite leaks/spills into groundwater for each calendar year were

documented in the Annual Radiological Environmental Operating Report for the REMP,

or the Annual Radiological Effluent Release Report for the RETS.

For significant, new effluent discharge points (such as significant or continuing leakage

to groundwater that continues to impact the environment if not remediated), the

inspectors evaluated whether the ODCM was updated to include the new release point.

b. Findings

No findings were identified.

.7 Problem Identification and Resolution (02.07)

a. Inspection Scope

The inspectors assessed whether problems associated with the Effluent Monitoring and

Control Program were being identified by the licensee at an appropriate threshold, and

23

were properly addressed for resolution in the licensee CAP. In addition, the inspectors

evaluated the appropriateness of the corrective actions for a selected sample of

problems documented by the licensee involving radiation monitoring and exposure

controls.

b. Findings

No findings were identified.

4. OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Security

4OA1 Performance Indicator Verification (71151)

.1 Mitigating Systems Performance IndexHigh Pressure Injection Systems

a. Inspection Scope

The inspectors sampled licensee submittals for the Mitigating Systems Performance

Index (MSPI) - High Pressure Injection Systems (MS07) PI for the period from the third

quarter 2014 through the second quarter 2015. To determine the accuracy of the PI

data reported during those periods, PI definitions and guidance contained in Nuclear

Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator

Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the

licensees operator narrative logs, CRs, MSPI derivation reports, event reports and NRC

Integrated IRs for the period of July 1, 2014, through June 30, 2015, to validate the

accuracy of the submittals. The inspectors reviewed the MSPI component risk

coefficient to determine if it had changed by more than 25 percent in value since the

previous inspection, and if so, that the change was in accordance with applicable

NEI guidance. The inspectors also reviewed the licensees CR database to determine if

any problems had been identified with the PI data collected or transmitted for this

indicator. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one MSPI - High Pressure Injection System sample as

defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance IndexResidual Heat Removal System

a. Inspection Scope

The inspectors sampled licensee submittals for the MSPI - Residual Heat Removal

System (MS09) PI for the period from the third quarter 2014 through the second

quarter 2015. To determine the accuracy of the PI data reported during those periods,

PI definitions and guidance contained in NEI 99-02, Regulatory Assessment

Performance Indicator Guideline, Revision 7, dated August 31, 2013, were used. The

inspectors reviewed the licensees operator narrative logs, CRs, MSPI derivation reports,

24

event reports and NRC Integrated IRs for the period of July 1, 2014, to June 30, 2015, to

validate the accuracy of the submittals. The inspectors reviewed the MSPI component

risk coefficient to determine if it had changed by more than 25 percent in value since the

previous inspection, and if so, that the change was in accordance with applicable NEI

guidance. The inspectors also reviewed the licensees CR database to determine if any

problems had been identified with the PI data collected or transmitted for this indicator.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one MSPI - Residual Heat Removal System sample as

defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Reactor Coolant System Specific Activity

a. Inspection Scope

The inspectors sampled licensee submittals for the reactor coolant system specific

activity PI for Palisades Nuclear Plant for the period from the fourth quarter 2014 through

the second quarter 2015. The inspectors used Performance Indicator definitions and

guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator

Guideline, Revision 7, dated August 2013, to determine the accuracy of the PI data

reported during those periods. The inspectors reviewed the licensees reactor coolant

system chemistry samples, TS requirements, CRs, event reports, and NRC Integrated

IRs to validate the accuracy of the submittals. The inspectors also reviewed the

licensees CR database to determine if any problems had been identified with the PI

data collected or transmitted for this indicator. Documents reviewed are listed in the

Attachment to this report.

This inspection constituted one reactor coolant system specific activity sample as

defined in IP 71151-05.

b. Findings

No findings were identified.

.4 Reactor Coolant System Leakage

a. Inspection Scope

The inspectors sampled licensee submittals for the Reactor Coolant System Leakage PI

for the period from the fourth quarter 2014 through the second quarter 2015. To

determine the accuracy of the PI data reported during those periods, PI definitions and

guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator

Guideline, Revision 7, dated August 31, 2013, were used. The inspectors reviewed the

licensees operator logs, Reactor Coolant System leakage tracking data, CRs, event

reports, and NRC Integrated IRs for the period of the fourth quarter 2014 through the

second quarter 2015 to validate the accuracy of the submittals. The inspectors also

reviewed the licensees CR database to determine if any problems had been identified

25

with the PI data collected or transmitted for this indicator. Documents reviewed are

listed in the Attachment to this report.

This inspection constituted one reactor coolant system leakage sample as defined in

IP 71151-05.

b. Findings

No findings were identified.

.5 Occupational Exposure Control Effectiveness

a. Inspection Scope

The inspectors sampled licensee submittals for the Occupational Exposure Control

Effectiveness PI for the period from the second quarter 2014 through the second

quarter 2015. The inspectors used PI definitions and guidance contained in NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 7, dated

August 2013, to determine the accuracy of the PI data reported during those periods.

The inspectors reviewed the licensees assessment of the PI for occupational radiation

safety to determine if indicator related data was adequately assessed and reported. To

assess the adequacy of the licensees PI data collection and analyses, the inspectors

discussed with radiation protection staff, the scope and breadth of its data review and

the results of those reviews. The inspectors independently reviewed electronic personal

dosimetry dose rate and accumulated dose alarms and dose reports, and the dose

assignments for any intakes that occurred during the time period reviewed to determine

if there were potentially unrecognized occurrences. The inspectors also conducted

walkdowns of numerous locked high and very high radiation area entrances to determine

the adequacy of the controls in place for these areas. Documents reviewed are listed in

the Attachment to this report.

This inspection constituted one occupational exposure control effectiveness sample as

defined in IP 71151-05.

b. Findings

No findings were identified.

.6 Radiological Effluent Technical Specification/Offsite Dose Calculation Manual

Radiological Effluent Occurrences

a. Inspection Scope

The inspectors sampled licensee submittals for the RETS/ODCM radiological effluent

occurrences PI for the period from the third quarter 2014 through the second

quarter 2015. The inspectors used PI definitions and guidance contained in NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 7, dated

August 2013, to determine the accuracy of the PI data reported during those periods.

The inspectors reviewed the licensees CR database and selected individual reports

generated since this indicator was last reviewed to identify any potential occurrences

such as unmonitored, uncontrolled, or improperly calculated effluent releases that may

have impacted offsite dose. The inspectors reviewed gaseous effluent summary data

26

and the results of associated offsite dose calculations for selected dates to determine if

indicator results were accurately reported. The inspectors also reviewed the licensees

methods for quantifying gaseous and liquid effluents and determining effluent dose.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one RETS/ODCM radiological effluent occurrences sample

as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA2 Identification and Resolution of Problems (71152)

.1 Routine Review of Items Entered into the Corrective Action Program

a. Inspection Scope

As part of the various baseline IPs discussed in previous sections of this report, the

inspectors routinely reviewed issues during baseline inspection activities and plant

status reviews to verify they were being entered into the licensees CAP at an

appropriate threshold, that adequate attention was being given to timely corrective

actions, and that adverse trends were identified and addressed. Attributes reviewed

included: identification of the problem was complete and accurate; timeliness was

commensurate with the safety significance; evaluation and disposition of performance

issues, generic implications, common causes, contributing factors, root causes,

extent-of-condition reviews, and previous occurrences reviews were proper and

adequate; and that the classification, prioritization, focus, and timeliness of corrective

actions were commensurate with safety and sufficient to prevent recurrence of the issue.

Minor issues entered into the licensees CAP as a result of the inspectors observations

are included in the Attachment to this report.

These routine reviews for the identification and resolution of problems did not constitute

any additional inspection samples. Instead, by procedure they were considered an

integral part of the inspections performed during the quarter and documented in

Section 1 of this report.

b. Findings

No findings were identified.

.2 Daily Corrective Action Program Reviews

a. Inspection Scope

In order to assist with the identification of repetitive equipment failures and specific

human performance issues for follow-up, the inspectors performed a daily screening of

items entered into the licensees CAP. This review was accomplished through

inspection of the stations daily CR packages.

These daily reviews were performed by procedure as part of the inspectors daily plant

status monitoring activities and, as such, did not constitute any separate inspection

samples.

27

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion (71153)

.1 Event Notification for Spill of Sewage from Chemical Toilet

a. Inspection Scope

The inspectors reviewed the plants response to an Event Notification for a Spill of

Sewage from a Chemical Toilet on July 13, 2015. The inspectors reviewed the

licensees actions to assess and report the spill. The spill occurred during a rainstorm

with high winds which caused the chemical toilet to tip over and spill. The spill had no

impact on plant operations. The inspectors also reviewed the Material Safety Data

Sheet for the chemicals involved and the licensees notifications of government agencies

to validate appropriate actions were taken and notifications were made. Documents

reviewed are listed in the Attachment to this report.

This event follow-up review constituted one sample as defined in IP 71153-05.

b. Findings

No findings were identified.

4OA5 Other Activities

.1 Contingency Plans for Licensee Strikes or Lockouts (IP 92709)

a. Inspection Scope

The United Government Security Officers of America Local 29 contract ended on

July 1, 2015. The contract was extended multiple times past this date to continue

negotiations between the licensee and union officials. Prior to the extended contract end

date of August 21, 2015, the resident inspectors and Region III security specialists

developed a strike/lockout contingency plan. The inspectors reviewed the licensees

strike/lockout preparations, including staffing and training. A verbal agreement was

reached between the union and Entergy on August 21, 2015, and was ratified on

August 24, 2015, without a strike/lockout. These activities constituted one sample as

defined in IP 92709.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On October 29, 2015, the inspectors presented the inspection results to Mr. A. Vitale,

Site Vice President, and other members of the licensee staff. The licensee

acknowledged the issues presented. The inspectors confirmed that none of the potential

report input discussed was considered proprietary.

28

.2 Interim Exit Meetings

Interim exits were conducted for:

• The inspection results for the areas of radioactive gaseous and liquid effluent

treatment; and reactor coolant system specific activity, occupational exposure

control effectiveness, and RETS/ODCM radiological effluent occurrences PI

verification with Mr. A. Vitale, Site Vice President, on July 17, 2015.

The inspectors confirmed that none of the potential report input discussed was

considered proprietary. Proprietary material received during the inspection was returned

to the licensee.

ATTACHMENT: SUPPLEMENTAL INFORMATION

29

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

A. Vitale, Site Vice President

A. Williams, General Manager Plant Operations

B. Baker, Operations Manager Support

T. Mulford, Operations Manager

R. Craven, Senior Manager Production

B. Dotson, Licensing Specialist

T. Davis, Licensing Specialist

O. Gustafson, Regulatory and Performance Improvement Director

J. Hardy, Regulatory Assurance Manager

J. Haumersen, Senior Manager Projects

D. Malone, Emergency Preparedness Manager

W. Nelson, Training Manager

K. OConnor, Engineering Design Manager

J. Borah, Engineering Systems and Components Manager

G. Heisterman, Senior Maintenance Manager

M. Schultheis, Performance Improvement Manager

C. Plachta, Nuclear Independent Oversight Manager

P. Russell, Engineering Director

J. Tharp, Security Manager

D. Nestle, Radiation Protection Manager

M. Soja, Interim Chemistry Manager

K. Strickland, Environmental Specialist

Nuclear Regulatory Commission

E. Duncan, Chief, Branch 3

Attachment

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened

Failure to Justify Continued Service of Safety-Related

Electrolytic Capacitors Installed Beyond Their Service Life

05000255/2015003-01 NCV

(Section 1R15)

Failure to Establish, Implement, and Maintain the Offsite

05000255/2015003-02 NCV

Dose Calculation Manual (Section 2RS6.5.b)

Closed

Failure to Justify Continued Service of Safety-Related

Electrolytic Capacitors Installed Beyond Their Service Life

05000255/2015003-01 NCV

(Section 1R15)

Failure to Establish, Implement, and Maintain the Offsite

05000255/2015003-02 NCV

Dose Calculation Manual (Section 2RS6.5.b)

Discussed

None

2

LIST OF DOCUMENTS REVIEWED

The following is a partial list of documents reviewed during the inspection. Inclusion on this list

does not imply that the NRC inspector reviewed the documents in their entirety, but rather that

selected sections or portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

1R04 Equipment Alignment

- CR0PLP-2014-04910, Perform A Radiographic Examination of the CV-1655, Condensing Unit

VC-11 Service Water Control, Valve Body, October 6, 2014

- CR-PLP-2014-02801, Tube Leak Discovered in E-901, Raw Water Heat Exchanger,

April 26, 2014

- CR-PLP-2014-03090, CV-0821, CCW Heat Exchanger E-54A Temp Control Positioner Has a

Small Air Leak, May 19, 2014

- CR-PLP-2014-03563, Main Lube Oil Bearing Supply Temperature is High, June 30, 2014

- CR-PLP-2014-03602, P-7A Basket Strainer High D/P Alarm, July 3, 2014

- CR-PLP-2014-03607, P-7C Pump Shaft in the Area of the Packing was Worn in an Hour Glass

Shape, July 3, 2014

- CR-PLP-2014-04427, UT Measured Pipe Thickness Fell Below the Screening Criteria,

September 10, 2014

- CR-PLP-2014-04502, While Performing Work on Service Water Pump P-7A Under

WO #52474416-03, Some Problems Were Encountered, September 15, 2014

- CR-PLP-2014-04959, Maintenance Performed on the Pump P-7A Affected the Current

Vibration Reference Values for the Test, October 12, 2014

- CR-PLP-2014-4401, Corrective Actions Associated with CR-PLP-2012-05813 Were Ineffective

in the Prevention of Service Water Leaks Due to Cavitation, September 10, 2014

- CR-PLP-2015-00348, Service Water Side of the Lube Oil Cooler (E-31B) on Emergency

Diesel Generator 1-2 East Side End Bell Cover Had Experienced Some Deep Corrosion in

Some Areas of the Sealing Gasket, January 21, 2015

- CR-PLP-2015-00355, Copper Tubing Exiting Critical Service Water Piping Immediately

Upstream of Control Valve CV-0885 (D/G 102 Service Water Inlet) Has a Pin Hole Leak,

January 21, 2015

- CR-PLP-2015-00967, Engineering Review Has Determined that Credible New Information

Exists that Potentially Challenges the Conservatism of Current Flooding Design Assumptions

or Requirements, March 3, 2015

- CR-PLP-2015-01229, MV-SW176, K-7B Lube Oil Cooler E-24D Service Water Inlet Has an

Active Packing Leak of 6 Drops Per Minute, March 23, 2015

- CR-PLP-2015-01573, Ultrasonic Thickness Measurements Less Than Tmin for Piping

JB-1-10 Between E-15B and MV-SW201, April 15, 2015

- CR-PLP-2015-02177, P-7C Packing Shaft Was Excessively Worn in the Area Where the

Packing Seals Against the Packing Shaft, May 27, 2015

- CR-PLP-2015-02578, E-15A Turbine Generator K-1 Main Lube Oil Cooler, West End Bell Has

Approximately a 2.5-3 Gallon Per Hour Service Water Leak, June 23, 2015

- CR-PLP-2015-03178, DPS-1319 SWS PP P-7A Basket Strainer Hi Differential Pressure

Switch is Alarming, July 31, 2015

- CR-PLP-2015-03404, P-7A Service Water Pump Packing Leakage Has Been Elevated and

Has Required Daily Packing Adjustments, August 15, 2015

- CR-PLP-2015-03953, C-903A, Feedwater Purity Building Air Compressor Oil Pressure at

18 psi with ESOMS Minimum of 20 psi, September 18, 2015

3

- CR-PLP-2015-04012, Alarm EK-1105 (Air Compressor Standby Comp Running)

Unexpectedly, September 19, 2015

- CR-PLP-2015-04037, Standby Compressor Started Despite Normal Operating Pressure in

System, September 20, 2015

- CR-PLP-2015-04122, C-903B Feedwater Purity Building Air Compressor Has Oil Leaking

From Copper Tube Fitting, September 22, 2015

- Drawing M-214, Sheet 1, Lube Oil, Fuel Oil, and Diesel Generating Systems, Revision 69

- EC 5000121478, Replace Service Water Supply and Discharge Piping & Components for CR

HVAC Condenser VC-10, Revision 2WT-PLP-2013-0324, Track Completion of Actions in

Service Water Top Ten Action Plan, December 17, 2013

- EN-DC-136, EC-36294, Augmentation of Existing Proceduralized TM (SOP-19, Instrument Air

System, Att. 6, Supply Service Air Header with Temporary Compressor) to Allow Rapid

Realignment of IA Compressor C-2C, Revision 6

- M-203, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,

Sheet A, Revision 7

- M-203, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,

Sheet 2, Revision 27

- M-204, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,

Sheet A, Revision 8

- M-204, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,

Sheet 1A, Revision 43

- M-204, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,

Sheet 1, Revision 84

- M-204, System Diagram Safety Injection, Containment Spray and Shutdown Cooling System,

Sheet 1B, Revision 41

- M-208, Piping & Instrument Diagram, Non-Critical Service Water System, Sheet 1,

Revision 105

- M-208, Piping & Instrument Diagram, Service Water System, Sheet 1A, Revision 65

- M-208, Piping & Instrument Diagram, Service Water system, Sheet 1B, Revision 38

- M-212, Piping & Instrument Diagram; Service & Instrument Air System, Sheet 1, Revision 83

- M-213, Piping & Instrument Diagram, Service Water, Screen Structure and Chlorinator,

Revision 95

- SEP-SW-PLP-002, Service Water & Fire Protection Inspection Program, Revision 3

- SOP-12, Auxiliary Feedwater System Checklist, Revision 73

- SOP-15, Service Water System, Revision 60

- SOP-19, Instrument Air System, Revision 64

- SOP-3, Safety Injection and Shutdown Cooling System, Revision 100

- WO 384456, Replace MV-SW136; E-54B SW Outlet CV-028 Bypass

- WO 384458, Replace MV-SW-282; Control Room HVAC Condenser VC-10 SW Outlet

- WO 384459, Replace MV-SW283; Control Room HVAC Condenser VC-10 SW Inlet

- WO 52325906, CV-0826; Replace Valve Assembly

1R05 Fire Protection

- Admin 4.49, Non-Power Operation Fire Risk Management, Revision 0

- EN-DC-127, Control of Hot work & Ignition Sources, Revision 15

- EN-DC-161, Control of Combustibles, Revision 13

- EN-DC-359, Fire Risk Management During Non-Power Operations for NFPA 805 Plants,

Revision 1

- Palisades Nuclear Plant Fire Hazards Analysis, Revision 7

4

- Pre Fire Plan 10/Rooms 001, 001A, 001B, & 004, East Engineered Safeguards Room,

Elevation 570 & 579

- Pre Fire Plan 16 / Room 123, Component Cooling Pump Room, Elevation 590

- Pre Fire Plan 16 / Room 238, Component Cooling Pump Room, Elevation 607 6

- Pre Fire Plan 16 / Room 338, Component Cooling Pump Room, Elevation 625

- Pre Fire Plan 29, 30, & 31 / Mechanical Equipment Rooms, Elevation 629-2 & 639

- Pre Fire Plan 6 / Rooms 116B & 147, Diesel Generator 1-2 and Fuel Oil Day Tank Room,

Elevation 590, 607, & 625

- Pre Fire Plan 9 / Room 13, Screen House/Intake Structure, Elevation 590

- Refueling Outage 1R24 Fire Protection Log 2014

1R06 Flood Protection

- CR-PLP-2015-00585, Improperly Sized Sprinkler Heads Replaced in Cable Spreading Room,

February 4, 2015

- CR-PLP-2015-03229, Eleven Inches of Water and Submerged Cables Discovered During

MH-8 Cable and Manhole Inspection, August 3, 2015

- DBD-2.05, Reactor Protective System Safety Injection Signal Anticipated Transient Without

Scram, Revision 7

- DBD-7.08, Plant Protection Against Flooding, Revision 6

- EN-WM-105, MH-4 Inspection Electrical, Revision February 3, 3007

- EN-WM-105, MH-8 Cable & Manhole Inspection, Revision February 3, 2007

- WO 52575326, D/GS and D Bus Floor Drain Flow Verification

1R11 Licensed Operator Requalification Program

- CR-PLP-2015-03464, Documentation of Coastdown Commencing on August 25, 2015,

August 20, 2015

- EOP Supplement 1, Pressure Temperature Limit Curves, Revision 5

- EOP Supplement 2, PCS Cooldown Strategy, Revision 2

- EOP-1.0, Standard Post-Trip Actions, Revision 16

- EOP-2.0, Reactor Trip Recovery, Revision 13

- GOP-8, Power Reduction and Plant Shutdown to Mode 2 or Mode 3 525°F, Revision 36

- GOP-9, Mode 3525°F to Mode 4 or Mode 5, Revision 36

- PNT 17.0 Attachment 2, Form PNF-17-SES, Simulator Exam Scenario SES-115 Revision 4,

Revision 5

- PO-2, PCS Heatup/Cooldown Operations, Revision 7

- SOP-1B, Primary Coolant System - Cooldown, Revision 19

- SOP-2A, Chemical and Volume Control System

1R12 Maintenance Effectiveness

- AOP-32, Loss Of Containment Integrity, Revision 0

- CIS-M-6, Personnel Air Lock Seal Contact Adjustment, Revision 0

- CR-PLP-2010-05643, Excessive Leakage on Inner Door Seal During DWO-13 LLRT-Local

Leak Rate Tests for Inner and Outer Personnel Air Lock Door Seals, October 26, 2010

- CR-PLP-2011-01048, Inner Door Leakage Was High During Performance of Personnel Air

Lock Test, DWO-13, March 3, 2011

- CR-PLP-2011-03574, Inner Door Leakage Was 3650 sccm During Performance of DWO-13

LLRT-Local Leak Rate Tests for Inner and Outer Personnel Air Lock Door Seals, July 20, 2011

5

- CR-PLP-2011-07003, Determine if There is a Method to Compensate for the Non-Uniform

Seal Grooves and Compression Set of Seal Material or Document Acceptability of Continuing

Under Current Conditions, December 22, 2011

- CR-PLP-2013-01894, Inner Door Leak Rate was 9011 sccm Per Step During DWO-13

LLRT-Local Leak Rate Tests for Inner and Outer Personnel Air Lock Door Seals,

April 26, 2013

- CR-PLP-2013-01965, During Performance of DWO-13, LLRT for Inner and Outer Personnel

Air Lock Doors, Inner Door Test Pressure Would Not Return to 10.5-11.5 psig, May 1, 2013

- CR-PLP-2014-00254, AOP-32, Loss of Containment Integrity Was Not Entered When Entry

Conditions Were Met, January 15, 2014

- CR-PLP-2014-05929, Assignment of Responsible Manager for Category C, Non-Significant

CR, December 29, 2014

- CR-PLP-2014-05929, During Local Leak Rate Test Inner Door Leakage Determined to be

5438 scfm With An Acceptance Criteria of Less Than or Equal to 3474 scfm,

December 23, 2014

- CR-PLP-2014-05929, Ensure That Condition Documented in CR-PLP-2014-05930 is

Appropriately Addressed Within the Scope of Corrective Action Plan, December 29, 2014

- CR-PLP-2015-00911, Evaluate Design of Inner and Outer Personnel Airlock (MZ-19) Seals,

May 7, 2015

- CR-PLP-2015-03181, Entered AOP-32 for Inoperable Containment Inner Airlock Door,

July 31, 2015

- CR-PLP-2015-03279, MZ-19 Inner Airlock Door Declared Inoperable Due to Excessive

Leakage, August 6, 2015

- DBD-2.09, Containment Building, Revision 4

- DR-PLP-2015-00911, Excessive Leakage Excessive During Local Leak Rate Test of Inner

Personnel Air Lock Door, February 27, 2015

- DWO-13, LLRT - Local Leak Rate Tests for Inner and Outer Personnel Air Lock Door Seals,

Revision 26

- EN-DC-205, Functional Failure Determination Form for CR-PLP-2013-01965, Revision 4

- EN-DC-205, Functional Failure Determination Form, Revision 5

- EN-LI-118, Equipment Failure Evaluation, Revision 21

- EN-LI-119, Apparent Cause Evaluation Report for Failure of Personnel Air Lock Leak Rate

Testing, Revision 1

- EN-MA-123, Rework Investigation Template for CR-PLP-2013-01965, Revision 5

- WO 407323 01, MZ-19, Inner Door Leakage Was Excessive Repair Seal

- WO 418803 01, MZ-19, Adjust Inner Door Seal (Contingency)

1R13 Maintenance Risk Assessments and Emergent Work Control

- AOP-30, Loss of Shutdown Cooling, Revision 1

- CR-PLP-2015-03144, NRC Inspector Identified Concern With the Number of Tie-Downs

Securing Shielded Cast to Trailer During Purification Demineralizer Filter Change Out,

July 28, 2015

- CR-PLP-2015-03682, Diver in Tilt Pit Received Alarm on an Extremity, Informational,

Non-Whole Body Electronic Dosimeter, September 3, 2015

- CR-PLP-2015-03683, Discovered Galled Locking Cylinder Bracket Bolt During Removal of

Locking Cylinder from the Spent fuel Side Upender, September 4, 2015

- CR-PLP-2015-03690, East Side Top Bolt Galled During Installation During Reassembly of

Spent Fuel Side Upender Locking Cylinder, September 4, 2015

- CR-PLP-2015-04133, Implementation of EN-DC-161 During HRPOS, September 22, 2015

- CR-PLP-2015-04156, CRDM Located at Position A11 Was Found Stuck, September 22, 2015

6

- EN-DC-161, Control of Combustibles, Revision 13

- EN-DC-359, Fire Risk Management During Non-Power Operations for NFPA 805 Plants,

Revision 1

- EN-IS-123, Electrical Safety, Revision 14

- EN-MA-118, Foreign Material Exclusion, Revision 10

- EN-MA-119, Material Handling Program, Revision 23

- EN-MA-127, Conduct of Diving Operations, Revision 9

- EN-OP-116, Infrequently Performed Tests For Evolutions, Revision 12

- EN-RP-151, Radiological Diving, Revision 3

- FPIP-4, Fire Protection Systems and fire Protection Equipment, Revision 34

- OL-PLP-2014-0026, ORAT RO-24, Revision 1

- Procedure 4.49, Non-Power Operation Fire Risk Management, Revision 0

- Refueling Outage 1R24 Fire Protection Log

- RFL-D-11, Uncouple CRDMs and Raise Rack Extensions, Revision 8

- WI-RSD-R-016, Replacement of Purification Demineralizer Filter, Revision 11

- WO 2424601, H-13, Rebuild and Reinstall SFP Side Upender Locking Cylinder

- WO 381087, N-50, Uncouple CRDMs and Raise Rack Extensions

- WO 386059, 72-13, Replace DC Contactor and Install Current Limiting Fuses

- WO 409729, H-5, Inspect Wheels and Structure of Fuel Transfer Cart

- WO 52549986, F-54A, Replacement of Filter Prior to 1R24

1R15 Operability Determinations and Functionality Assessments

- AOP-29, PCP Abnormal Conditions, Revision 4

- ARP-5, PCP Steam Generator and Rod Drives Scheme EK-09 (C-12), Revision 102

- Calculation # E48-LE-01, Transamerica Delavel Containment Level Element, Revision 12

- CR-PLP-2011-01341, NRC Identified Concern With Regards to Part 21 Document During the

Deferral of Governor Replacement, March 18, 2011

- CR-PLP-2012-05721, NRC Issued IN 2012-11: Age-Related Capacitor Degradation on

July 23, 2012, August 16, 2012

- CR-PLP-2014-05918, MO-45 Control Room Channel Checks are Close to Being Outside

Acceptance Criteria, December 21, 2014

- CR-PLP-2015,03064, Clarification Required in Maintenance Rule Scoping Document for

Containment Level Instrumentation, July 22, 2015

- CR-PLP-2015-00596, Trend in P-50A Oil Level, February 5, 2015

- CR-PLP-2015-00757, Safety Injection Tank T-82C Pressure Transmitter Spiking,

February 17, 2015

- CR-PLP-2015-00998, Open Indicating Light for CV-0944A Failed to Light, March 6, 2015

- CR-PLP-2015-01007, Unexpected Primary Makeup Tank T-81 Hi-Lo Alarm, March 8, 2015

- CR-PLP-2015-01133, Containment Radiation Monitor RIA-1817 Warning Light is Illuminated,

March 16, 2015

- CR-PLP-2015-01236, Unexpected Charging Low Flow Alarm EK-0735, March 25, 2015

- CR-PLP-2015-01943, Safety Injection Tank T-82B Vent Valve CV-3065, May 12, 2015

- CR-PLP-2015-01994, Fire Protection Review of Oil Leak on PCP 50A, May 14, 2015

- CR-PLP-2015-02559, Containment Level Indicating Transmitter Found to be Indicating Below

the Minimum Required, June 21, 2015

- CR-PLP-2015-02828, Received EK-0949, P-50A Seal Pressure Off-Normal, July 6, 2015

- CR-PLP-2015-02946, Oily Smell and Film Detected During Dewatering Setup, July 13, 2015

- CR-PLP-2015-03285, Based on Repair of LIT-0446B, Initiate A WO to Perform Same Repairs

to LIT-0446A, August 6, 2015

7

- CR-PLP-2015-03536, LIT-0446A Containment Level Transmitter Indicator, A Level Indication

Appears Erratic On the PPC, August 26, 2015

- CR-PLP-2015-03547, LIT-0446A, LIT-0446B Containment Floor Level Transmitters Do Not

Meet the Acceptance Criteria of MO-45, August 27, 2015

- CR-PLP-2015-04972, Failure to Justify Continued Service of Safety-Related Electrolytic

Capacitors Installed Beyond Their Service Life, October 13, 2015

- DBD-2.04, Primary Coolant System, Revision 8

- DBD-7.02, Appendix A, Table A-1, EQ Master Equipment List, Revision 13

- EN-DC-153, Preventive Maintenance Component Classification, Revision 12

- EN-DC-205, Functional Failure Determination Form for CR-PLP-2015-02559, Revision 5

- EN-WM-105, Remove LIT-0446A to Bench to Replace Convertor Capacitor, June 21, 2011

- EOP-4.0, Loss-of-Coolant Accident Recovery Basis, Revision 14

- EOP-4.0, Loss-of-Coolant Accident Recovery, Revision 23

- EOP-9.0, Functional Recovery Procedure, Revision 22

- FSAR Chapter 7, Instrumentation and Controls, Revision 31

- MO-45, Control Room Channel Checks, Revision 10

- Oil Level Trends, P-50A, 2006-2015

- Operations Aggregate List, August 24, 2015

- Operator Burden, Primary Makeup Tank T-81 Auto Makeup Capability Does Not Work,

June 26, 2015

- Operator Burden, Safety Injection Tank T-82B Vent Valve CV-3065Not Working Properly,

June 10, 2015

- PLO-RPT-12-00026, EGAD-EP-10, Palisades Maintenance Rule Scoping Document,

Revision 0

- PNP 2015-058, Technical Specification Required Report, August 3, 2015

- RI-68, Containment Water Level and Sump Level Monitor Calibration, Revision 12

- Vendor Document M0001EB-0856, Allis Chalmers PCP Motor

- WO 380046, LIT-0446B; Replace LIT Water Level Transmitter Drifting

1R19 Post-Maintenance Testing

- CR-PLP-2015-03092, Amber Light for LTRI-0101A Heater Power Supply Failed During

Performance of MI-43, July 23, 2015

- CR-PLP-2015-04299, New Valve Procured to be Installed as CV-0826 CCW HX E-54B SW

Outlet Does Not Match the Configuration of the Valve Removed, September 25, 2015

- CR-PLP-2015-04380, CV-0826 CCW HX E-54B SW Outlet Failed Leakage Test,

September 27, 2015

- CR-PLP-2015-04562, Unable to Fully Evaluate Post-Maintenances Diagnostic Testing on

CV-0826 Due to Failure to Collect Torque Data, October 1, 2015

- CVCO-4, Periodic Test Procedure - Charging Pumps, Revision 7

- EC-60236, Evaluation of Alternate Valve Disc Hard Stop Configuration for CCW Heat

Exchanger (E-54B) Service Water Outlet Valve CV-0826, Revision 0

- EN-MA-143, Use of VIPER or VOTES Infinity Air Operator Valve Diagnostics, Revision 4

- M-208, Piping & Instrument Diagram Service Water System, Sheet 1A, Revision 65

- MI-43, Reactor Vessel Level Monitoring System Channel Check, Revision 18

- QO-5, Valve Stroke Testing Data Sheet, CV-0821, CV-0822, CV-0826, Attachment 17,

Revision 94

- WO 00384456 04, Replace MV-SW136, SW Outlet CV-0826 Bypass

- WO 52325906 01, CV-0826, CCW HX E-54B SW Outlet Valve Replace Vale

- WO 52436026 02, CV-0821, Inspect Valve and Repair or Replace as Necessary

- WO 52436027 04, CV-0822, Inspect Valve and Repair or Replace as Necessary

8

- WO 52541561 02, CV/VOP-0915; Diagnostic Testing (Return To Service)

- WO 52617441 01, MI-43 Reactor Vessel Level Monitoring System Channel Check

1R20 Outage Activities

- Admin 4.49, Non-Power Operation Fire Risk Management, Revision 0

- AOP-25, Loss of Refueling Water Accident, Revision 0

- AOP-26, Loss of Spent Fuel Pool Cooling, Revision 2

- AOP-30, Loss of Shutdown Cooling, Revision 1

- AOP-34, Fuel Handling Accident, Revision 0

- CR-2015-04249, Penetration MZ-30, Containment Spray Pump Discharge was Not Listed on

GOP-14, Attachment 12, September 25, 2015

- CR-PLP-2014-04909, Create a WO to Internally Inspect the Entire Length of the Intake Pipe

and the Lakebed Immediately Above the Intake Pipe, October 10, 2014

- CR-PLP-2014-04924, Replace Power Cables Between EX-04 and 2400 V Busses 1C and 1D

With Larger Higher Amp Rated Cables, October 10, 2014

- CR-PLP-2015-03039, Fire Risk Management During Non-Power Operations for NFPA 805

Plants Have Not Been Fully Implemented in the Outage Schedule, July 20, 2015

- CR-PLP-2015-03469, Leakage Identified on MV-SW137, East ESS Room Cooler VHX-27A

Outlet, August 20, 2015

- CR-PLP-2015-03840, Oil Build Up Observed Under Fill Port that Leads to Site Glass and

Sample Tube on Primary Cooling Pump 50A, September 16, 2015

- CR-PLP-2015-03842, Oil Sample Obtained from the Upper Reservoir of PCP Motor 50B Was

Found to be Darker in Color Than the Rest of the Samples Taken, September 16, 2015

- CR-PLP-2015-03848, Oil Samples for the P-50A PCP Motor and P-50C PCP Motor Were

Taken With the Motors Running, September 16, 2015

- CR-PLP-2015-03864, Mode 3 Walkdown - CRD-36, September 17, 2015

- CR-PLP-2015-03876, SPI Reading for Rod 27 Was Found to be Reading 30 Prior to Rod

Movements, September 17, 2015

- CR-PLP-2015-03882, Problem Identified on Spent Fuel Handling Machine During Dummy

Fuel Bundle Moves, September 17, 2015

- CR-PLP-2015-03884, Mode 3 Walkdown - MV-CVC2296, September 16, 2015

- CR-PLP-2015-03885, Mode 3 Walkdown - MV-CVC2299, September 17, 2015

- CR-PLP-2015-03886, Mode 3 Walkdown - MV-ES3009, September 17, 2015

- CR-PLP-2015-03887, Mode 3 Walkdown - MV-ES3010A, September 17, 2015

- CR-PLP-2015-03889, Mode 3 Walkdown - MV-ES3109A, September 17, 2015

- CR-PLP-2015-03890, Mode 3 Walkdown - MV-ES3125A, September 17, 2015

- CR-PLP-2015-03895, Mode 3 Walkdown - CV-1015, September 16, 2015

- CR-PLP-2015-03896, Mode 3 Walkdown - MO-3011, September 17, 2015

- CR-PLP-2015-03897, Mode 3 Walkdown - CV-1013, September 16, 2015

- CR-PLP-2015-03899, Mode 3 Walkdown - MV-SFP505, September 16, 2015

- CR-PLP-2015-03902, Mode 3 Walkdown - MV-CRW113, September 16, 2015

- CR-PLP-2015-03903, Mode 3 Walkdown - MO-3068, September 17, 2015

- CR-PLP-2015-03904, Mode 3 Walkdown - MV-CRW112, September 16, 2015

- CR-PLP-2015-03906, Repair Workers Calculated Corrected Load Value for Input to the

Battery Capacity Computer Test System Multiplied Correction to the Uncorrected Load vs the

Procedural Step, September 27, 2015

- CR-PLP-2015-03915, Mode 3 Walkdown - CRD-40, September 18, 2015

- CR-PLP-2015-03916, Mode 3 Walkdown - CRD-17, September 18, 2015

- CR-PLP-2015-03920, Mode 3 Walkdown - T-72, September 18, 2015

- CR-PLP-2015-03921, Mode 3 Walkdown - MV-PC1068, September 18, 2015

9

- CR-PLP-2015-03922, Mode 3 Walkdown - P-50B, September 18, 2015

- CR-PLP-2015-03923, mode 3 Walkdown - P-50A, September 18, 2015

- CR-PLP-2015-03926, Mode 3 Walkdown - CV-2202, September 18, 2015

- CR-PLP-2015-03927, Mode 3 Walkdown - CV-3038, September 18, 2015

- CR-PLP-2015-03931, Control Valve CV-0608 for the Moisture Separator Drain Tank Level

Controls Did Not Stroke as Expected, September 18, 2015

- CR-PLP-2015-03933, Red Indication Lamp on Escape Airlock Door is Malfunctioning,

September 18, 2015

- CR-PLP-2015-03945, Issues Identified During E-30B System Engineer Cooling Tower

Walkdown, September 18, 2015

- CR-PLP-2015-03956, Mode 3 Walkdown of the PCS 590 Elevation, September 16, 2015

- CR-PLP-2015-03958, Operations Noted on Cameras That a Cable Was Routed Through the

Recently Opened Equipment Hatch, September 18, 2015

- CR-PLP-2015-03960, Mode 3 Walkdown - MV-CC110, PCP P-50A, September 16, 2015

- CR-PLP-2015-03961, Mode 3 Walkdown - MV-CC112, PCP P50B, September 16, 2015

- CR-PLP-2015-03962, Mode 3 Walkdown - MV-CC196, September 16, 2015

- CR-PLP-2015-03964, Mode 3 Walkdown - P-50C, September 16, 2015

- CR-PLP-2015-03965, Mode 3 Walkdown - PCP P-50C, September 16, 2015

- CR-PLP-2015-03966, Mode 3 Walkdown - T-64C, September 16, 2015

- CR-PLP-2015-03967, Mode 3 Walkdown - RV-1041, PZR T-72, September 16, 2015

- CR-PLP-2015-03968, Mode 3 Walkdown - Pressurizer Shed on the 649 Elevation,

September 16, 2015

- CR-PLP-2015-03969, Mode 3 Walkdown - P-50A, September 16, 2015

- CR-PLP-2015-03970, Alignments Between Work Group and Operations Were Not Precise,

September 18, 2015

- CR-PLP-2015-03970, During Performance of RFL-D-3 Open Equipment Hatch, Alignments

Between the Work Group and Operations Were Not Concise, September 18, 2015

- CR-PLP-2015-03971, Mode 3 Walkdown - P-50B, PCP, September 16, 2015

- CR-PLP-2015-03972, Mode 3 Walkdown - MV-PC1137, P-50C FE-0143A,

September 16, 2015

- CR-PLP-2015-03973, Mode 3 Walkdown - T-64B, September 16, 2015

- CR-PLP-2015-03975, Mode 3 Walkdown - VHX-4, September 16, 2015

- CR-PLP-2015-03976, Mode 3 Walkdown - CRD-37, September 16, 2015

- CR-PLP-2015-03977, Mode 3 Walkdown - CRD-41, September 16, 2015

- CR-PLP-2015-03990, NDE Activities on L-1/:D-1, September 19, 2015

- CR-PLP-2015-04022, CV-3057 Solenoid Valve is Not Functioning Properly,

September 20, 2015

- CR-PLP-2015-04023, Category 5 Air Leak on the Diaphragm of CV02111,

September 20, 2015

- CR-PLP-2015-04050, Concentrate Boric Acid Storage Tank, T-53A is Above the Refueling

Mode Admin Limit of 15,000-ppm, September 20, 2015

- CR-PLP-2015-04052, Mode 3 Walkdown - MO-3012, September 20, 2015

- CR-PLP-2015-04053, Mode 3 Walkdown - MO-3008, September 20, 2015

- CR-PLP-2015-04059, Mode 3 Walkdown - CRD-45, September 21, 2015

- CR-PLP-2015-04061, During Performance of RFL-D-8, CRDM Tool Access Flange Removal,

Control Room SRO Approval Was Not Obtained, September 21, 2015

- CR-PLP-2015-04066, Drain Line for RV-0707 Was Found Broken During Valve Removal,

September 21, 2015

- CR-PLP-2015-04070, Gaps Identified During Performance of the Turbine Stop Valve Cover

Lift, September 21, 2015

10

- CR-PLP-2015-04076, Signal Person and Crane Operator Were Not in Constant

Communication During One Portion of the Turbine Stop Valve Cover Removal,

September 21, 2015

- CR-PLP-2015-04079,CV-1059 Failed Drop Test, September 21, 2015

- CR-PLP-2015-04085, CV-2099, PCP Controlled Bleed Off Containment Isolation, Diagnostic

Testing Performed With Out Communications to Operations Personnel, September 21, 2015

- CR-PLP-2015-04090, CV-0701 and CV-0703 Actuator Stems and Bushings are Worn and

Require Replacement, No Parts Available, September 22, 2015

- CR-PLP-2015-04092, Drop Test Failed During As-Left Testing to Check CV-2099 PCP

Controlled Bleed Off Containment Isolation, September 22, 2015

- CR-PLP-2015-04096, BTV-0610 Internal Inspection Reveals Damage to Disc Causing it to Lay

Sideways, September 22, 2015

- CR-PLP-2015-04109, As Found Testing Results at the Upper End of its Acceptance Criteria,

September 22, 2015

- CR-PLP-2015-04116, RV-0775 Failed to Lift With an Acceptance Range of 1265 to 1465 psi,

September 22, 2015

- CR-PLP-2015-04123, One Worker on Scaffold Building Crew Was Not FME qualified,

September 22, 2015

- CR-PLP-2015-04130, B Channel AFAS Power Supply Appears to be Bad,

September 22, 2015

- CR-PLP-2015-04153, Loose Spindle Cap Identified During Offsite Testing and Repair of

RV-0703, September 23, 2015

- CR-PLP-2015-04155, ICI Flange 2 Cannot be Removed Due to What Appears to be a Bent

Connector, September 23, 2015

- CR-PLP-2015-04159, An FME Bladder Was Installed Into the Valve Body of Main Steam

Governor Valve #1 CV-0570 Without Logging it Into the FEM Log Book, September 23, 2015

- CR-PLP-2015-04163, RO-32-11 Exceeds Administrative Limit for Second Outage In A Row,

September 23, 2015

- CR-PLP-2015-04169, PCV-1492 Failed As-Left Testing and Cannot Be Repaired,

September 23, 2015

- CR-PLP-2015-04172, RO-32-42 Exceeds Administrative Limit for Second Outage in a Row,

September 23, 2015

- CR-PLP-2015-04178, There are No Lanyards Available to Workers In Containment,

September 23, 2015

- CR-PLP-2015-04180, Maintenance Activities on RV-0721, September 23, 2015

- CR-PLP-2015-04187, A High Pressure Turbine Rigging Hardware Interference Was Identified

While Rigging the HP Turbine K-1-HP Outer Cylinder for Removal, September 23, 2015

- CR-PLP-2015-04192, Magnetic Particle NDE Examinations on the L-1/LD-4 and Alloy 600

Projects, September 23, 2015

- CR-PLP-2015-04203, CV-0780 Failed a Drop Test by Dropping 7.5 Percent of Pressure,

September 24, 2015

- CR-PLP-2015-04204, CV-0781 Failed a Drop Test by Dropping Approximately 10.1 Percent of

Pressure Over 5 Minutes, September 24, 2015

- CR-PLP-2015-04218, Unable to Establish Required Flow Rate for Final Bundle Flush During

Draining and Filling the B Steam Generator, September 25, 2015

- CR-PLP-2015-04222, Foreign Material Exclusion is Not Meeting Requirements of EN-MA-118

for the Main Turbine Project, September 24, 2015

- CR-PLP-2015-04240, CV-1057 Pressurizer Spray Valve From Loop 1B Failed its Drop Test,

September 24, 2015

- CR-PLP-2015-04243, RP Technician Preparing to Enter Containment Was Not Signed in on

Tagging, September 23, 2015

11

- CR-PLP-2015-04246, P50A PCP Motor Lower Oil Reservoir Has Active Leak From Lower

Bearing Reservoir Gasket, September 25, 2015

- CR-PLP-2015-04248, During Venting, CV-3065, Safety Injection Tank T-82B Vent Valve,

Would Not Close, September 25, 2015

- CR-PLP-2015-04265, Errors Were Discovered Within EN-MA-119, Material Handling

Program Attachment 9.10, September 25, 2016

- CR-PLP-2015-04277, Packing End Rings Ordered for the AOV Stem Were Not the Proper

Size, September 25, 2015

- CR-PLP-2015-04278, Slowly Lowering Trend on T-3, CCW Surge Tank, September 25, 2015

- CR-PLP-2015-04281, Procedure HED-M-2 Requires Revision, September 25, 2015

- CR-PLP-2015-04282, Robot Disconnected From Tubesheet and Fell Into Bowl with No

Damage and All Loose Parts Accounted for, September 25, 2015

- CR-PLP-2015-04283, Feedwater Pump P-1A to SG E-50B Has Pipe Wall Thickness Readings

Below the Calculated Minimum, September 25, 2015

- CR-PLP-2015-04290, A Protected Equipment Boundary Was Found Not to be in Place in the

Cable Spreading Room, September 25, 2015

- CR-PLP-2015-04292, ED-16, Charger #2 for Station Battery #2 Would Not Transfer to

Equalize Charge Mode, September 25, 2015

- CR-PLP-2015-04293, Supplemental Workers Performing Main Feedwater Pump P-1A

Maintenance and Inspection Activities Were Observed Using Less Than Adequate Human

Performance Tools, September 25, 2015

- CR-PLP-2015-04295, Replacement Flange Found Not to be the Same as Old Flange During

Attempted Replacement on MV-FW166 Valve, September 25, 2015

- CR-PLP-2015-04302, Steam Erosion Found at the North East Corner of the K-1-HP Horizontal

Joint, September 25, 2015

- CR-PLP-2015-04319, As-Built Rigging Assembly Too Long for the HP Turbine Rotor,

September 26, 2015

- CR-PLP-2015-04339, GCA Oversight Seeing Minor Administrative Issues With FME Log

Keeping, September 26, 2015

- CR-PLP-2015-04343, Incorrect Size Sealtight Ordered For TE-0131A, September 26, 2015

- CR-PLP-2015-04357, Steam Leak Path Bypasses the Finger Seal, September 27, 2015

- CR-PLP-2015-04361, Permissive in Pelco Camera System Needs to be Removed Prior to

Start of Refueling Outage, September 27, 2015

- CR-PLP-2015-04368, New Piston Seals Were Not Like for Like in Repair of CV-3057,

September, 27, 2015

- CR-PLP-2015-04388, Wrong Packing Was Procured for CV-3001, September 27, 2015

- CR-PLP-2015-04391, As Found Condition of Valve Internals on CV-0780, S/G E-50B ASDV

Are Poor, September 27, 2015

- CR-PLP-2015-04392, Small Leak From Conduit Box on P-50D, September 27, 2015

- CR-PLP-2015-04396, Replacement Actuator Base Plate Does Not Match the Piece Removed

From VOP-3057, September 27, 2015

- CR-PLP-2015-04398, CV-2191 PCP Controlled Bleedoff Stop, Air Supply Regulator Failed,

September 28, 2015

- CR-PLP-2015-04400, Installed Flanges Were 300# and Replacement Flanges of 150# During

Performance of WO-00378591, September 28, 2015

- CR-PLP-2015-04404, Need to Determine Correct Replacement Part for Steam Element Due

to Mis-Marking, September 28, 2015

- CR-PLP-2015-04410, Packing Adjustment on MV-CC713 Was Unsuccessful,

September 28, 2015

- CR-PLP-2015-04421, Work Group Did Not Fully Barricade or Adequately Verify the Work Area

for the Main Condensate Pump (P-2A) Lift, September 28, 2015

12

- CR-PLP-2015-04434, Performed PCP P-50D Inspection of Lube Oil System and Oil Collection

System, September 28, 2015

- CR-PLP-2015-04435, Performed PCP P-50A Inspection of Lube Oil System and Oil Collection

System, September 28, 2015

- CR-PLP-2015-04436, Performed PCP P-50B Inspection of Lube Oil System and Oil Collection

System, September 28, 2015

- CR-PLP-2015-04438, Flange Leakage Drain, Leaked by at 3 GPM to the Primary System

Drain Tank with the Reactor Head Removed and the Cavity Flooded, September 29, 2015

- CR-PLP-2015-04462, PCV-3057B, T-58 Outlet CV-3057 Needs to Be Adjusted A/S REG

Setpoint, September 29, 2015

- CR-PLP-2015-04473, Containment Sump Check Valve Inservice Testing, Step 5.2.13.3 Was

Not Consistent With CK-ES3166 Data Review, September 29, 2015

- CR-PLP-2015-04481, New Style Kits for Replacement of Buses 1C, 1D, and 1B Feeder Cable

Replacement Projects, September 29, 2015

- CR-PLP-2015-04488, MV-ES3184, JPSI P-66A Suction Manual Valve Was Difficult to Operate

During a Tagout, September 29, 2015

- CR-PLP-2015-04505, ICI Locking Device Quick Disconnect on Flange Number 7

Disconnected, September 28, 2015

- CR-PLP-2015-04507, Valve Bellow at Maximum Procedural Tolerance, Valve Shows Erratic

Set Pressure Testing/Adjustment, and Valve Disc is Within Tolerance During as Left Testing

on RV-1041, September 30, 2015

- CR-PLP-2015-04511, Atmospheric Steam Dump Solenoid SV-0779A & SV-0782A did Not

Isolate When Expected During Functional Test, September 30, 2015

- CR-PLP-2015-04514, Two Air Compressors Providing Breathing Air to Steam Generator

Project are Within 10 Feet of Two Diesel Powered Water Pumps, September 30, 2015

- CR-PLP-2015-04521, Pen Cap Observed Floating in Reactor Cavity, September 29, 2015

- CR-PLP-2015-04533, Threads on the Valve Actuator Stem Were Sheared During Seat Load

Adjustment on CV-3038, September 30, 2015

- CR-PLP-2015-04534, CV-3065 Safety Injection Tank T-82B Vent Valve Internal Valve Stem

Guide Bushing Had Significant Corrosion Build Up, September 29, 2015

- CR-PLP-2015-04544, Minor Defects Identified on the Disk for CV-0781 That Will be Removed

Prior to Installation, October 1, 2015

- CR-PLP-2015-04547, Red and Green Lenses Mistakenly Swapped During Repair,

October 1, 2015

- CR-PLP-2105-03919, Battery Charger #1 (ED-15) Would Not Go Into Equalize,

September 18, 2015

- CR-PLP-2105-04297, Loads Being Flown Over Top of People, September 25, 2015

- DR-PLP-2015-04043, Air Leak Was Heard Around CV-3057, SIRW Tank Outlet Isolation

Valve During Containment Sump Check Valve Inservice Test, September 20, 2015

- EN-DC-127, Control of Hot Work & Ignition Sources, Revision 15

- EN-DC-161, Control of Combustibles, Revision 13

- EN-DC-319, Boric Acid Corrosion Control Program, Revision 11

- EN-DC-359, Fire Risk Management During Non-Power Operations for NFPA 805 Plants,

Revision 1

- EN-MA-118, Foreign Material Exclusion, Revision 10

- EN-MA-119, Material Handling Program, Revision 11

- EN-OM-123, Fatigue Management Program, Revision 11

- EN-OP-102, Protective and Caution Tagging, Revision 18

- EN-OP-116, Infrequently Performed Tests or Evolutions, Revision 12

- EN-OU-108, Shutdown Safety Management Program (SSMP), Revision 8

- EOP Supplement 1, Pressure Temperature Limit Curves, Revision 5

13

- FHS-M-23, Movement of Heavy Loads in the Spent Fuel Pool Area, Revision 36

- FHS-M-24, Movement of Heavy Loads in the Containment Building Area, Revision 38

- FPIP-1, Fire Protection Plan, Organization and Responsibilities, Revision 24

- GOP-11, Refueling Operations and Fuel Handling, Revision 48

- GOP-14, Shutdown Cooling Operations, Revision 49

- MSM-M-72, Movement of Heavy Loads in Turbine Building, Revision 1

- OL-OLPIP-2014-0026, ORAT, Revision 1

- PO-2, PCS Heatup/Cooldown Operations, Revision 7

- Report P2298-14-001, 1R24 Non-Power Operations Outage Assessment, Revision 0

- RFL-D-13, Reactor Pressure Vessel Head Detensioning, Revision 6

- RFL-D-16, Reactor Vessel Closure Head Removal, Revision 17

- RFL-D-19, Removal of UGS From Reactor Vessel, Revision 6

- RFL-D-3, Open Equipment Hatch, Revision 8

- RFL-SG-2, S/G Primary Nozzle Dam Installation and Removal, Revision 10

- SOP-1A, Primary Coolant System, Revision 28

- SOP-1B, Primary Coolant System - Cooldown, Revision 19

- SOP-3, Safety Injection and Shutdown Cooling system, Revision 100

- SOP-6, Reactor Control System, Revision 35

- WI-PCS-M-06, NSSS Walkdown, Revision 5

- WO# 00381087-14, N-50; Reactor Head Removal

- WO# 425-483-01, L-1/LD-1 Lift Rig NDE Inspection PM

1R22 Surveillance Testing

- Admin Procedure No. 4.19, PCS Leak Rate Monitoring Program, Revision 6

- CR-PLP-2014-01047, Steps of RT-8C, Attachment 1 Were Inadvertently Signed Off,

February 4, 2014

- CR-PLP-2014-01099, P-54C Would Not Start During RT-8C, February 5, 2014

- CR-PLP-2014-01108, Wavebook Failed to Capture Data in RE-139-1, February 6, 2014

- CR-PLP-2014-4463, PCS Leak Rate Greater than Three Standard Deviations From the Mean,

September 12, 2014

- CR-PLP-2014-4861, T-82B Alarm Received for Lo Level Unexpectedly, October 7, 2014

- CR-PLP-2015-02974, As Founds Were Out of Tolerance During RI-99 for Left Channel

Nuclear Instrumentation Calibrations, June 15, 2015

- CR-PLP-2015-02979, New Circuit Board Failed Upon Installation, June 16, 2015

- CR-PLP-2015-0323, Incorrect Data Reporting for PCS Primary-to-Secondary Leakage to

INPO, January 20, 2015

- CR-PLP-2015-03565, Minor Leaks Identified on VC-10 During RT-202 Control Room HVAC

Heat Removal Capability Test, August 28, 2015

- CR-PLP-2015-04043, CV-30057, SIRW Tank Outlet Isolation Valve Wouldnt Fully Open

During RO-141, September 20, 2015

- CR-PLP-2015-1501, Rising Trend in D SIT, April 12, 2015

- CR-PLP-2015-1737, Trending of PCS Indicates Measured Seal Leakage Rate for P-55A, A

Charging Pump, Experienced a Significant Increase, April 27, 2015

- CR-PLP-2015-2626, Primary System Drain Tank Has In-Leakage, June 24, 2015

- CR-PLP-2015-2683, PCS Leak Rate had Two of Last Three Consecutive Unidentified Leak

Rates Greater Than 2 Standard Deviations From the Baseline Mean, June 27, 2015

- CR-PLP-2015-3337, PCS Unidentified Leak Rate Exceeded Action Level 1 Deviation From

Baseline Mean, August 11, 2015

- CR-PLP-2015-3357, PCS Unidentified Leak Rate Exceeded Action Level 1 Deviation From

Baseline Mean, August 12, 2015

14

- DBD-2.09, Design Basis Document for Containment Building, Revision 4

- DRN-15-00774, SOP-30, Section 7.3.2, to Transfer from Safeguards/Station Power to Startup

Power, Step D.7., References the Wrong Procedure Section

- DWO-1, Operators Daily/Weekly Items Modes 1, 2, 3, and 4, Revision 105

- EN-DC-161, Control of Combustibles, Revision 10

- EN-MA-134, Offline Motor Electrical Testing, Revision 5

- EN-MA-135, Online Motor Electrical Testing, Revision 5

- EN-MA-153, Use of VIPER or VOTES Infinity Air Operator Valve Diagnostics, Revision 4

- MSI-I-16, Nonintrusive Diagnostic Check Valve Test Procedure (Using Viper/UDS Platform),

Revision 5

- Operations Daily Logs

- Operations Primary Coolant System Leak Rate Program Data Worksheet

- QO-16, Inservice Test Procedure - Containment Spray Pumps, Revision 35

- RE-139-2, Test Starting Time of Diesel Generator, Revision 12

- RI-99, Left Channel Nuclear Instrumentation Calibrations, Revision 14

- RO-105, Full Flow Test for SIT Check Valves and PCS Loop Check Valves, Revision 13

- RO-141, Containment Sump Check Valves Inservice Test, Revision 6

- RO-32-19, Local Leak Rate Test Procedure for Personnel Air Lock, Revision 9

- RT-202, Control Room HVAC Heat Removal Capability, Revision 15

- RT-8D, Engineered Safeguards System - Right Channel Basis Document, Revision 7

- SEP-CV-PLP-002, Check Valve Condition Monitoring and Inservice Testing Program,

Revision 2

- SOP-30, Station Power, Revision 76

- SPS-E-20, Maintenance for 2400 Volt Siemens Switchgear, Revision 6

- WO #380495, RO-141; Containment Sump Check Valve Testing

- WO #419812, T-74; Operations to Troubleshoot Where In-Leakage is Coming From

- WO 419858; NI-1/3A; Source Range Reading Upscale with Detector Disconnected

- WO 52537390-01, RT-8D Engineered Safeguards Sys-Right Channel

- WO 52538538, EMA-1114 (P-54C) Perform Online Motor Testing

- WO 52544830, CK-ES3131 & CK-ES3132, Nonintrusive Check Valve Testing

- WO 52558713, EEQ-EMA-1114, Containment Spray P-54C Motor

- WO 52561654-01, RO-105 - Full Flow Test for SIT Check Valves

- WO 52623508, QO-16C - P-54C, ISI Test Procedure, Containment Spray

1EP6 Drill Evaluation

- AOP-35, Loss of Service Water, Revision 0

- AOP-38, Acts of Nature, Revision 3

- CR-PLP-2015-03549, Sentinel Radiation Work Permit Log-In Station Did Not Function

Normally During EP Drill, August 26, 2015

- CR-PLP-2015-03554, Field Monitoring Team 2 Did Not Placekeep the Steps They Followed

While Performing Their Drill Duties, August 26, 2015

- CR-PLP-2015-03559, Four Emergency Preparedness Drill Participants Were Observed

Without Their Dosimetry of Legal Record During the EP Drill, August 27, 2015

- CR-PLP-2015-03567, Problems Encountered with Radio Communications

- CR-PLP-2015-03568, Cell Phones in Field Monitoring Team Vans had Dead Batteries During

Third Quarter 2015 Drill, August 28, 2015

- EI-6.13, Protective Action Recommendations for Offsite Populations, Revision 24

- Emergency Action Level Technical Basis, Revision 7

- EOP Supplement 2, PCS Cooldown Strategy, Revision 8

- EOP-1.0, Standard Post-Trip Actions, Revision 16

15

- EOP-5.0 Steam Generator Tube Rupture Recovery, Revision 18

- EOP-9.0, Functional Recovery Procedure, Revision 22

- Palisades Third Quarter Emergency Planning Drill, August 26, 2015

- SEP Supplement 1, EAL Wall Charts, Revision 2

2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

- 2013 Annual Radioactive Effluent and Waste Disposal Report, April 30, 2014

- 2014 Annual Radioactive Effluent and Waste Disposal Report, April 27, 2015

- CH 6.20, Radioactive Effluent Operating Procedure, Revision 3

- CH 6.21, Radioactive Liquid Release, Revision 8

- CH 6.41, Land Use Census, Revision 6

- COP-35, Groundwater Monitoring Program, Revision 5

- CR-PLP-2015-03000, RR-10-003 RETS Basis Document is Not Consistent With ODCM

Methodology, July 16, 2015

- CR-PLP-2015-2972, Failure to Incorporate Land Use Census Data Into Required Dose Rate

Calculations for Nearest Resident, July 15, 2015

- DWR-10, Stack Effluent Sampling and Calculations, Revision 41

- EN-CY-111, Radiological Groundwater Monitoring Program, Revision 6

- LO-PLPLO-2014-00153, 2015 RET PRE-NRC Assessment, May 26, 2015

- MR-35, Turbine Sump Collection and Calculation, Revision 16

- MR-36, Service Water Collection and Calculation, Revision 17

- ODCM, Appendix A, Relocated Technical Specifications per NRC Generic Letter 89-01 (TAC

NO 75060), Revision 18

- ODCM, Revision 26

- REMP RETS Basis Document, Number R10-002, Demonstrating Compliance with 40 CFR,

Part 190 Dose Limits, March 28, 2010

- RETS Basis Document, Number R09-001, Liquid Effluent Release Concentration Limit for

Dose Calculations, November 29, 2009

- RETS Basis Document, Number R10-001, T-91 Two-Tank Volume Recirculation Time Prior to

Sampling Justification, March 15, 2010

- RIA/RIA System Walkdown Checklist, June 30, 2015

- RIA/RIA System Walkdown Checklist, March 30, 2015

- RR 10-03, Predetermined Radioactive Liquid Releases Criteria, Revision 0

- RT-85C, Fuel Handling Area Ventilation System Filter Testing, Revision 12

- RT-85D, Control Room Emergency Ventilation Filtration Testing, Revision 16

- System Health Report, RIA-Radiation Monitoring System, Period Q1-2015

- System Health Report, RIA-Radiation Monitoring System, Period Q4-2014

- WO 52470171 01, RT-85C-SFP Ventilation HEPA & Charcoal Testing

4OA1 Performance Indicator Verification

- CR-PLP-2015-03834, NRC Resident Identified Three Errors in Data Validation Packages for

ROPS PCS Identified Leakrate Performance Indicator, September 16, 2015

- EN-LI-114; Performance Indicator Process; Revision 6

- NRC Performance Indicator Data; Reactor Coolant System Leakage; Fourth Quarter 2014

Through Second Quarter 2015

- NRC Performance Indicator Technique/Data Sheet, Mitigating Systems Performance Indicator,

High Pressure Injection (MS07), July 2014 Through June 2015

- NRC Performance Indicator Technique/Data Sheet, Mitigating Systems Performance Indicator,

Residual Heat Removal (MS09), July 2014 Through June 2015

16

- Operations Daily Logs

- Operations Primary Coolant System Leak Rate Program Data Worksheet

- Palisades MSPI Basis Document, December 21, 2011

4OA3 Follow-up of Events and Notices of Enforcement Discretion

- CR-PLP-2015-02928, Chemical Toilet Spill During Heavy Rain, July 13, 2015

- EN-51224, Event Notification Worksheet for Chemical Toilet Spill, July 13, 2015

- MSDS-Material Safety Data Sheet for Chemical Toilet, March 12, 2013

4OA5 Other Activities

- CR-PLP-2015-3403, Inconsistency in Meeting Intent of EN-NS-300 for Non-Palisades Security

Force Members Physical Agility Tests, August 15, 2015

- EN-NS-300, Security Training Program, Revision 5

- EN-NS-304, Security On-the-Job Training, Task Performance Evaluation, and Training

Exemptions, Revision 6

- EN-OM-123, Fatigue Management Program, Revision 11

- Palisades Staffing Contingency Plan

17

LIST OF ACRONYMS USED

10 CFR Title 10 of the Code of Federal Regulations

ADAMS Agencywide Documents Access Management System

CAP Corrective Action Program

CCW Component Cooling Water

CR Condition Report

ECCS Emergency Core Cooling System

IMC Inspection Manual Chapter

IN Information Notice

IP Inspection Procedure

IR Inspection Report

LIT Level Indicating Transmitter

MSPI Mitigating Systems Performance Index

NEI Nuclear Energy Institute

NCV Non-Cited Violation

NRC U.S. Nuclear Regulatory Commission

ODCM Offsite Dose Calculation Manual

ORAT Outage Risk Assessment

PARS Publicly Available Records System

PCP Primary Coolant Pump

PCS Primary Coolant System

PI Performance Indicator

RAS Recirculation Actuation Signal

REMP Radiological Environmental Monitoring Program

RETS Radiological Effluent Technical Specification

RFO Refueling Outage

SSC Structures, Systems, and Components

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

WO Work Order 18

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII RIII RIII RIII

NAME EDuncan:mp

DATE 10/30/15